TrustlessPay Digital Assets, Inc. – Global Anti‑Slavery and Human Trafficking Statement
Date: July 30, 2025
(This statement is made pursuant to the UK Modern Slavery Act 2015, Australian Modern Slavery Act 2018, and
California Transparency in Supply Chains Act, and is guided by the UN Guiding Principles on Business and Human Rights and ILO conventions.)
Introduction and Commitment
TrustlessPay Digital Assets, Inc. (“TrustlessPay”) is firmly committed to a zero-tolerance approach towards modern slavery, human trafficking, forced labor, and all forms of exploitation. We recognize that slavery and human trafficking are heinous crimes and violations of fundamental human rights present in every country.
As a global blockchain-based technology company, we are dedicated to conducting our business with integrity and ensuring that no part of our operations or supply chains involves or supports these abuses. This Statement affirms our corporate responsibility to prevent and eradicate any form of forced labor or trafficking in our sphere of influence, in compliance with applicable laws and in alignment with international standards. In particular, we uphold the principles of the UK Modern Slavery Act 2015 and the Australian Modern Slavery Act 2018, which require organizations like ours to report annually on steps taken to prevent modern slavery in our business and supply chains . We likewise meet the disclosure requirements of the California Transparency in Supply Chains Act, which mandates transparency about efforts to eradicate slavery and trafficking from our supply chain . Beyond legal compliance, TrustlessPay’s approach is informed by the UN Guiding Principles on Business and Human Rights, which call on businesses to carry out human rights due diligence to identify, prevent, mitigate, and account for how we address adverse human rights impacts . We also support the core conventions of the International Labour Organization (ILO) on forced labor and child labor, reflecting our commitment to international best practices in safeguarding human dignity.
In essence, TrustlessPay formally commits to doing all that we can to eliminate any risk of slavery, trafficking, or forced labor within our organization and our extended value chain. We have a zero tolerance policy for such abuses and expect the same high standards from all those we work with. This public Statement details our structure, policies, risk assessments, due diligence processes, training, and ongoing efforts to combat modern slavery and human trafficking, and it has been approved by our Board of Directors and signed by our Founder & CEO (as indicated at the end). We intend for it to be transparent, comprehensive, and in the spirit of the law’s purpose: to improve the lives of victims of slavery and
human trafficking through greater corporate accountability .
Company Overview, Structure and Supply Chains
TrustlessPay Digital Assets, Inc. is a blockchain-based financial technology company headquartered in Atlanta, Georgia (USA), with operations and partnerships spanning North America, Europe, Asia, and other regions. We build decentralized infrastructure and digital asset solutions for real-world finance, enabling secure and transparent financial services through distributed ledger technology. Our business model revolves around software development, digital asset management platforms, and collaborative innovation via decentralized networks.
Organizational Structure: TrustlessPay is a privately held corporation led by a Board of Directors and an executive leadership team. We have a core team of full-time employees based in our Atlanta headquarters and in regional offices worldwide. Additionally, we engage a network of contractors, consultants, and global service providers for specialized services (such as software development, cybersecurity, cloud infrastructure, and professional consulting). We also collaborate with decentralized communities and Decentralized Autonomous Organizations (DAOs) on certain open-source projects and protocols. While DAOs and similar partner communities are not traditional suppliers, we include them as part of our broad “supply chain” or value network for the purposes of this Statement, given that they contribute to our product and service ecosystem.
Supply Chains: Our supply chain primarily comprises goods and services that support our technology operations and corporate functions. This includes: hardware and IT equipment (e.g. servers or computers) procured from reputable vendors, software and cloud hosting services, office operations and facilities services, and various professional services. We also rely on global business partners (such as channel partners, integrations with other financial platforms, and liquidity providers) and open-source communities that help us deliver real-world financial solutions. Because our industry is digital, much of our “supply chain” involves intangibles (code, software, cloud infrastructure) and human expertise rather than physical goods; however, we remain vigilant that risks of modern slavery can still arise both in physical and digital contexts. We acknowledge that modern slavery and human trafficking can be hidden in any supply chain, whether through the labor used to manufacture electronics, the staffing of service vendors, or even the misuse of digital platforms by bad actors . Therefore, we assess risk across all facets of our operations – from our direct employees and contractors to our technology partners, vendors, and decentralized collaborators.
Definitions of Modern Slavery and Human Trafficking
For clarity and purpose of this Statement, TrustlessPay adopts the following definitions consistent with international standards and law:
Slavery: The condition of treating a person as property, effectively exercising powers of ownership over an individual.
Servitude: A situation where a person is obligated to provide services and is unable to change that condition due to coercion.
Forced or Compulsory Labor: All work or service which is exacted from any person under the menace of any penalty and for which that person has not offered themselves voluntarily . In essence, this means work that people are coerced to do against their free will, under threat of punishment. This includes practices such as debt bondage, forced child labor, and other forms of coerced work.
Human Trafficking: The recruitment, transportation, transfer, harboring, or receipt of persons by means of threat, force, coercion, abduction, fraud, or deception for the purpose of exploitation. This includes sexual exploitation, forced labor, slavery or practices similar to slavery, servitude, or the removal of organs. In the context of the Modern Slavery Act, human trafficking is defined as arranging or facilitating the travel of another person with a view to their exploitation .
Collectively, “modern slavery” encompasses all of the above activities – slavery, servitude, forced labor, and human trafficking – as well as related practices like child labor and debt bondage. TrustlessPay is committed to combating all such forms of exploitation. We understand that these crimes often operate in the shadows, and part of our duty is to increase transparency and vigilance to ensure they are not present in any part of our business or supply chain. All four of the above activities are addressed in this Statement, in line with the expectation that a slavery and human trafficking statement should cover the full spectrum of modern slavery issues .
Policies and Internal Governance
At TrustlessPay, we have implemented robust policies and governance structures to prevent any incidence of modern slavery or human trafficking within our operations and those of our business partners. Our approach is values-driven, legally sound, and backed by senior leadership commitment.
Corporate Policies: We maintain a comprehensive Code of Ethical Business Conduct that explicitly prohibits any form of forced labor, child labor, human trafficking, or exploitation in our business and supply chain. This code establishes the expectation that all employees, contractors, and business partners uphold the highest standards of human rights and labor practices. We have formally communicated to our staff and stakeholders that compliance with anti-slavery laws and our internal policy is a condition of doing business with TrustlessPay. We regularly review and update our policies to ensure they remain effective and in line with evolving best practices and legal requirements.
Supplier Code of Conduct: In addition to our internal code, we have a Business Partner/Supplier Code of Conduct that mirrors our zero-tolerance stance on modern slavery. All TrustlessPay vendors, service providers, and partners (including those in decentralized networks where formal agreements exist) are required to adhere to this code. It mandates that suppliers do not use or tolerate any form of forced or involuntary labor, child labor, or human trafficking in any aspect of their operations or supply chain . We incorporate this requirement into our procurement contracts, vendor onboarding materials, and partner agreements. Each supplier or partner must certify or contractually agree that any goods or services provided to TrustlessPay are in compliance with applicable laws regarding slavery and human trafficking in the countries where they operate . Where appropriate, we seek certifications from direct suppliers affirming that the materials, products, or services they provide are produced without slavery or trafficking and in compliance with all relevant laws . Our contracts also include clauses that give TrustlessPay the right to terminate the relationship if the supplier is found to be engaging in or condoning modern slavery.
Governance and Oversight: Ultimate responsibility for our anti-slavery efforts lies with our Board of Directors and executive leadership. This Statement has been reviewed and approved by the Board, ensuring top-level oversight. We have assigned specific accountability for implementation to our Compliance and Ethics Committee, which includes representatives from our Legal, Operations, and Procurement departments. This committee meets regularly to evaluate the effectiveness of our modern slavery prevention measures, review any reported concerns, and drive continuous improvement. The committee provides updates to the Board and recommends actions or policy enhancements as needed. By having board-level approval and a designated senior officer sign this Statement, we ensure leadership accountability and that combating modern slavery receives the “serious attention it deserves” at the highest levels.
Risk-Based Ethics Approach: Our corporate governance framework embeds human rights risk considerations into business decisions. We conduct risk assessments (described in detail below) and integrate the findings into our governance processes. If higher-risk areas are identified, they are subject to enhanced scrutiny and mitigation plans, which are overseen by management and reported to the Board. Our ethos is that ethical considerations, including the fight against modern slavery, are never sacrificed for profit or convenience – a principle championed by our leadership and reflected in our corporate culture of responsibility and transparency.
Whistleblower Protection: To reinforce our governance, TrustlessPay has a strong stance on whistleblower protection and ethical reporting. We maintain a confidential and anonymous Whistleblower Hotline (operated by an independent third party) that is available to all employees, contractors, and even external parties to report any suspicions or evidence of unethical behavior, including concerns about forced labor or trafficking, without fear of retaliation . Our Whistleblower Policy assures that anyone who raises concerns in good faith will be protected from retaliation or adverse action. We encourage a “speak up” culture where individuals can approach management or use the hotline to report any red flags regarding modern slavery. All reports are taken seriously and investigated promptly by our Legal and Compliance team, with findings reported to the appropriate senior management and, if necessary, to the Board’s Audit/Compliance Committee. This mechanism helps ensure that potential issues are identified and addressed early. (See the section Reporting and Remediation below for more on how we handle reports.)
Risk Awareness and Assessment in Our Operations
TrustlessPay continuously assesses the risk of modern slavery and human trafficking in both our digital and physical operational environments. Given the nature of our business – digital finance and technology – we recognize that our risk profile may differ from companies in manufacturing or agriculture; however, no company is risk-free. We approach risk assessment with vigilance and a broad perspective, examining every area where people are involved in or impacted by our operations.
Risk in Direct Operations (Workforce): We consider the risk of modern slavery within our direct workforce to be low, due to several mitigating factors. TrustlessPay employs highly skilled professionals (engineers, developers, finance and compliance experts, etc.) under transparent employment agreements, with competitive salaries and working conditions. We conduct rigorous hiring due diligence, including verifying each employee’s legal right to work and ensuring no indication of coercion or exploitative conditions. We apply consistent recruitment standards globally, and most hiring is done in-house, which helps maintain oversight . Our employees work in office and remote environments by choice and are free to leave under the terms of their employment—these conditions make forced labor practices extremely unlikely. Nonetheless, we remain alert to any signs of exploitation such as unethical labor intermediaries or abusive practices, especially in regions with higher prevalence of labor abuses . We have not identified any instances of forced labor or trafficking in our own operations to date, and we continually monitor to keep it that way.
Risk in Supply Chain (Physical Goods & Services): We acknowledge that certain tiers of our supply chain could pose elevated risks. For example, any hardware or electronics we procure (servers, laptops, etc.) may have complex supply chains that extend into regions with known labor rights challenges (such as conflict minerals or factories with poor labor practices). We source such equipment from leading manufacturers who publish their own modern slavery statements and we consider their ethical sourcing practices as part of our vendor selection. We remain aware that industries like electronics manufacturing have been identified by global studies as at risk of forced labor . Similarly, any facility services (like office cleaning or security, if outsourced) could carry risks if vendors employ low-wage or migrant workers – groups that can be vulnerable to exploitation. We mitigate this by conducting due diligence on service providers (requiring they adhere to fair labor standards and verifying they pay employees lawfully and provide safe conditions). Geographic risk is also a factor: while our primary suppliers are in the U.S. and other low-risk jurisdictions, we do utilize some services or talent in countries where enforcement of labor laws is less stringent. As part of our risk mapping, we take into account the country-level risk indices for modern slavery and focus extra attention on any suppliers in higher-risk locations.
Risk in Digital and Decentralized Environments: As an innovator in decentralized finance, TrustlessPay is particularly mindful of risks that might not be present in traditional supply chains. One such risk is the misuse of digital platforms for human exploitation. We recognize that criminals and traffickers sometimes exploit financial systems and technology to facilitate their illicit operations (for instance, using cryptocurrency services to launder money that could finance human trafficking rings) . While this is not a risk of forced labor within our company, it is a human trafficking risk enabled by digital financial platforms. Therefore, we consider it our responsibility to put barriers against such misuse. (Our response is described under Due Diligence below, notably through robust Anti-Money Laundering controls.) Additionally, in working with open-source projects and DAOs, there is a potential risk regarding the labor ethics of those contributors – for example, if any external contributor or independent community we collaborate with were found to be using forced labor or coercive practices in their own operations. The decentralized nature of these organizations can make oversight challenging. We address this by carefully selecting the decentralized projects we formally partner with, favoring those with transparent governance and good reputations, and by treating them similarly to vendors for the purpose of risk assessment. We also remain attentive to the cybersecurity risk that traffickers could attempt to use our platforms for illegal communications or transactions; while this strays from traditional “modern slavery in supply chain” definitions, we consider any such potential abuse of our technology as part of the human rights risks we must mitigate.
Identified High-Risk Areas: Based on our risk assessment this year, the following areas have been identified as priority risks for monitoring and mitigation:
Use of TrustlessPay’s Services for Illicit Purposes: As noted, the potential misuse of our financial products or digital asset platform by bad actors for laundering funds linked to trafficking is a risk we consider high. Modern slavery operations often rely on moving illicit funds covertly; hence any financial service could be targeted for abuse.
Third-Party Contractors and Outsourcing: While our core staff are low-risk, we do work with contingent workers and outsourced service providers (e.g. for technical support, content moderation, or customer service in some regions). There is a risk that these third-party labor providers could engage in unethical recruitment (such as debt bondage of workers or confiscation of worker passports). We deem this a moderate risk and have included it in due diligence checks. Hardware and Equipment Supply Chain: As mentioned, manufacturing supply chains for IT hardware can involve forced labor deeper in the tiered supply chain (for instance, raw material mining or assembly factories). Though we are not a hardware company, we take this risk seriously for the products we do purchase, in line with global concern that hundreds of billions of dollars in goods worldwide may be tainted by forced labor .
Regional Operations: We operate or have partnerships in a variety of countries. Some countries (according to the Global Slavery Index and other benchmarks) have higher prevalence of forced labor or weaker enforcement. We identified a few such locations in our extended operations and are focusing additional attention there. (For example, if we were to engage tech consultants in a country with lower labor protections, we would treat that as higher risk.)
For each of these areas, we have devised specific mitigation strategies, described in the next section.
Due Diligence and Prevention Measures
TrustlessPay employs a thorough due diligence process to assess, prevent, and address modern slavery and trafficking risks identified in our operations and supply chains. Our approach is proactive and multifaceted, following the framework of “identify, evaluate, mitigate, monitor” as recommended by international guidelines . Below we outline our key measures:
Supplier and Partner Due Diligence: Before onboarding any new significant vendor, contractor, or business partner, we perform risk-based due diligence. This process includes:
- Risk Screening: We evaluate the prospective supplier’s industry, geographic location, and any available information on their labor practices. Suppliers in industries or countries with higher modern slavery risk are flagged for enhanced scrutiny. We also check for any human rights controversies or sanctions related to the entity.
- Self Assessment and Verification: For higher-risk suppliers, we may require them to complete a self assessment questionnaire regarding their labor practices, or to provide documentation of their own anti slavery policies and training. In some cases, we utilize independent third-party verifications or request existing audit reports to validate the supplier’s compliance with ethical standards (if such audits have been done for them).
- Contractual Controls: As noted under Policies, all supplier contracts include clauses prohibiting the use of forced or trafficked labor and requiring compliance with all applicable anti-slavery laws. We also include a requirement that suppliers flow down these obligations to their sub-suppliers, ensuring the commitment is cascaded through the supply chain. Many suppliers are asked to certify compliance with these standards and laws as a condition of doing business.
- Supplier Code Acknowledgment: Suppliers must acknowledge our Supplier Code of Conduct, which reinforces
expectations like fair wages, safe working conditions, no retention of identity papers, no recruitment fees charged to workers, etc., in addition to the ban on forced labor. We obtain an affirmative commitment from the supplier on these points.
- Ongoing Monitoring: We maintain a vendor management system that tracks our suppliers and their risk profiles. Higher-risk vendors are reviewed more frequently. We stay alert to any news or reports of human rights issues at key suppliers. Internally, we assign risk ratings to vendors to facilitate appropriate oversight and monitoring throughout the relationship. If a supplier’s risk profile elevates (for instance, due to an incident in their operations or a negative report), we may re-engage with them, request remedial action, or re-evaluate the relationship.
Audits and Assessments: TrustlessPay reserves the right to conduct audits of suppliers where justified. For critical suppliers in higher-risk categories, we will consider on-site or virtual audits either by our team or qualified third parties to inspect working conditions and verify compliance with anti-slavery requirements. We prioritize collaborative audits – aiming to work with suppliers on improvements – but will not hesitate to enforce compliance. (At this time, given our supply chain’s nature, we have not found it necessary to conduct any surprise audits; however, the policy and capability are in place should conditions warrant.) We also welcome our clients or partners to inquire about our own practices, and we are prepared to undergo similar assessments or provide information to assure them of our compliance.
Addressing Risks in Decentralized Partnerships: For DAOs or open-source projects where formal audits are not straightforward, our due diligence relies on community reputation and governance transparency. We thoroughly research any decentralized project we align with, ensuring they have no known association with illicit activities or exploitative practices. If a DAO has identifiable leadership or jurisdiction, we engage in dialogue about our expectations on ethical conduct. In collaborative projects, we advocate for incorporating fair labor standards in any funded work. While this is an emerging area, we are committed to extending our due diligence ethos into the decentralized realm as much as possible.
Anti-Money Laundering (AML) and Platform Safeguards: To combat the risk of our digital financial platforms being used to facilitate trafficking or slavery, TrustlessPay has implemented a rigorous AML/CFT compliance program. This program is designed in line with global best practices and regulatory requirements (including guidance from bodies like the Financial Action Task Force). Key elements include: - Customer due diligence (Know Your Customer checks) to verify the identity and legitimacy of our platform users. - Transaction monitoring systems that flag unusual or suspicious transactions. Our systems are calibrated to detect patterns that might indicate money laundering or the movement of funds related to crime, including human trafficking. - Strict adherence to economic sanctions and watchlists (we screen customers and transactions against U.S. and international sanctions lists, which often include traffickers and criminal organizations). - Reporting of suspicious activities to relevant authorities as required by law. We cooperate fully with law enforcement investigations of human trafficking and do not hesitate to file Suspicious Activity Reports (SARs) if we suspect our services are being misused in connection with such crimes. - An AML policy that explicitly mentions preventing the facilitation of human trafficking finances as an objective, and periodic training for our compliance staff on detecting human trafficking red flags in financial transactions.
By maintaining these controls, we strive to prevent TrustlessPay’s products and infrastructure from being “used to facilitate money laundering, which could be used to finance human trafficking or other modern slavery practices” **. Our risk-based approach means we allocate greater compliance resources to higher-risk areas of our business and continually evaluate our controls for effectiveness in addressing modern slavery risks in the digital domain.
Remediation Processes: In the unfortunate event that we discover an instance of modern slavery or trafficking in our operations or supply chain, TrustlessPay is prepared to respond swiftly and effectively. Our remediation steps would include: - Taking immediate action to safeguard the impacted individual(s) – for example, if a worker is found in conditions of coercion at a supplier, we would work with that supplier (or appropriate authorities) to ensure the person’s safety and freedom. - Engaging with the supplier or partner to understand the situation and require corrective measures. This could involve the supplier eliminating fees, returning passports to workers, improving conditions, or ceasing relationships with abusive sub suppliers. We would set a clear timeline for remediation. - If the supplier does not cooperate or the situation is severe, we would suspend or terminate the business relationship. Zero tolerance means we will not continue to benefit from or contribute to a situation of slavery. - Reporting the incident to law enforcement or relevant authorities if appropriate, especially in cases of human trafficking, so that perpetrators can be investigated and prosecuted. - Reflecting on the incident to strengthen our systems: performing a root cause analysis to see if there were warning signs we missed, and updating our due diligence processes or training to prevent future occurrences. - Cooperating with any NGOs or victim support organizations to ensure that victims receive assistance, compensation, or access to remedy, in line with the ILO principles and UN Guiding Principles emphasis on access to justice for victims. Our policy is to not obstruct victims from seeking remedies and to support lawful processes to help them.
So far, TrustlessPay has not identified any confirmed cases of modern slavery or human trafficking linked to our business. Should that change, we will be transparent about the issue and our actions taken, consistent with our commitment to disclosure and improvement.
Training and Capacity Building
We recognize that policies and processes are only as effective as the people implementing them. Therefore, training and awareness are critical components of TrustlessPay’s anti-slavery efforts. We strive to ensure that all relevant employees and partners understand the risks of modern slavery and know how to act if they encounter it.
Employee Training: TrustlessPay provides training to all employees on our Code of Conduct, which includes modules on human rights and modern slavery. New hires receive onboarding training covering our zero tolerance policy toward forced labor and trafficking. In addition, we conduct specialized training for employees in key functions such as procurement, vendor management, human resources, and compliance. These team members receive in-depth instruction on how to identify warning signs of modern slavery in supply chains or employment (e.g. recognizing signs of worker distress, document retention, or recruiting fees), how to use our due diligence tools, and how to escalate any concerns. We update this training regularly to include current case studies and evolving best practices. By equipping our staff with knowledge, we enable them to be the “eyes and ears” that can spot and stop potential issues.
For example, our supply chain management and procurement teams are trained in the specifics of verifying and auditing suppliers for compliance with anti-slavery standards . They learn about what verification steps we expect (and that if a third-party verification is not used, that must be noted) , how to conduct or arrange supplier audits, and how to review supplier certifications of compliance. They also receive guidance on engaging in constructive dialogue with suppliers about these issues.
Management and Executive Engagement: Our leadership and managers receive tailored briefings to ensure they understand the importance of this issue and their role in championing it. The tone from the top is clear: ethical conduct and human rights are a priority. Managers are trained to communicate our stance to their teams and to intervene immediately if any problem is suspected. Modern slavery prevention is also part of our wider training on corporate social responsibility and risk management, which our executives attend.
Contractor and Partner Awareness: Where possible, we extend training or awareness resources to our key contractors and business partners. We share our policies and expectations, and in some cases invite contractor representatives to attend internal training sessions or provide them with informational materials. For our open-source community engagements, we publish our stance and encourage those communities to adopt similar values, though formal training in that context is challenging.
Ongoing Awareness Initiatives: Throughout the year, we reinforce awareness through internal communications. This includes informational articles on our intranet (for instance, explaining the signs of trafficking or reporting on World Day Against Trafficking in Persons events), posters in offices reminding people of the whistleblower hotline, and engaging employees during October (which in some jurisdictions is Anti-Slavery Day/Month) with seminars or guest speakers. We aim to create a culture where ethical vigilance is second nature.
Our goal is that 100% of employees in relevant roles receive modern slavery awareness training. We track training completion as a key performance indicator. We are proud to report that in the past year, all employees with procurement or supply chain duties were trained on identifying and addressing slavery risk, and overall over 95% of our staff completed their annual ethics training which included human trafficking content. We plan to reach full coverage next year and continuously improve the depth and impact of our training.
Reporting, Monitoring and Whistleblower Protections
As mentioned earlier, TrustlessPay has established channels to report concerns and a strict non-retaliation policy. Here we provide more detail on how we monitor compliance and encourage reporting, as well as how we measure the effectiveness of our anti-slavery efforts.
Safe Reporting Mechanisms: We maintain multiple avenues for reporting any suspicion of modern slavery:
- Confidential Whistleblower Hotline: Operated 24/7 by an independent provider, available online and by phone, in multiple languages, so that employees, suppliers, or any external party can report issues anonymously if they choose . This hotline is advertised internally and on our website.
- Open Door Policy: Employees are encouraged to report concerns to their manager or directly to HR or the Compliance team without fear. We have an open door culture and actively remind staff that raising concerns is a responsibility and will be met with support, not retaliation.
- Supplier Reporting: We ask our suppliers to also communicate any concerns. Our Supplier Code of Conduct includes contact information for reporting ethics issues. Suppliers and partners can reach out to our compliance department if they see or experience any situation of concern, whether within our operations or in their dealings on our behalf.
Protection and Response: When a report is made, our trained investigators (from Legal/Compliance) promptly review the allegation. We ensure confidentiality is maintained. If the report involves a supplier, we may engage our procurement and legal teams to investigate collaboratively. No retaliatory action will be taken against anyone making a good-faith report – this is clearly stated in our Whistleblowing Policy and reinforced by senior leadership. Should any employee attempt to retaliate against a whistleblower, that in itself would be treated as a serious disciplinary matter.
Monitoring and KPIs: To gauge how well we are doing in combating modern slavery, TrustlessPay uses several key performance indicators (KPIs) and monitoring activities:
- Training Completion Rates: (As noted, we track the percentage of staff trained in relevant modern slavery topics, aiming for 100% in target groups.)
- Supplier Due Diligence Coverage: We monitor what proportion of our key suppliers have undergone risk assessment and signed our Code of Conduct or provided required certifications. Currently, 100% of new high-risk suppliers in the last year were screened and agreed to our anti-slavery terms. Our goal is to maintain full coverage and re-screen existing suppliers on a rolling basis.
- Incidents and Resolutions: We track the number of reported concerns related to modern slavery or trafficking. In the
reporting period, zero incidents were substantiated within our operations or supply chain. (We did receive two inquiries via the hotline regarding labor practices of a subcontractor, which upon investigation were found to be concerns unrelated to modern slavery but rather general labor conditions; still, we provided feedback to the subcontractor for improvement.) We also track remediation actions – since no actual slavery cases were found, no remediation was needed, but our preparedness is assessed through drills and scenario planning.
- Audit Findings: If we conduct any supplier audits, we record any non-compliances and track closure of those findings. In this period, we did not initiate new audits due to the relatively low risk in our current supplier base, but we plan to develop this as our supply chain grows.
- Effectiveness Reviews: Our Compliance Committee conducts an annual review of our anti-slavery program effectiveness. This includes reviewing the above KPIs, benchmarking our practices against industry standards, and identifying areas for improvement. For instance, we compare our Statement and practices with those of peer companies to ensure we are meeting or exceeding common commitments.
- External Feedback: We also pay attention to external ratings or feedback. If any NGO, customer, or regulator provides input on our modern slavery efforts (for example, via a modern slavery register or inquiries), we include that in our assessment.
Through these monitoring tools, we aim to ensure that our policies are not just on paper but are making a tangible difference. The government guidance encourages companies to include KPIs to help readers assess effectiveness , and we embrace that by being transparent about our performance and goals.
Future Steps and Continuous Improvement
TrustlessPay is dedicated to the continuous improvement of our anti-slavery and human trafficking measures. Modern slavery is an evolving and complex challenge, and we know that our response must also evolve. In the coming year, we are committed to the following goals and initiatives:
Enhancing Supply Chain Transparency: We plan to leverage technology to gain better visibility into the deeper tiers of our supply chain. For example, we are exploring blockchain-based supply chain traceability solutions (fittingly, as a blockchain company) to ensure ethical sourcing of any physical products we use . While our supply chain is not as extensive as a manufacturing company’s, we believe even tech companies can benefit from innovative tools to trace and verify supplier practices.
Supplier Engagement Program: We will roll out an engagement program for our critical suppliers, including webinars or workshops on combating modern slavery. This will help smaller vendors understand the issue and build their capacity to manage risks, creating a partnership approach to tackling slavery.
Joining Industry Initiatives: We intend to join at least one industry collaborative initiative or pledge on human rights (such as the Tech Against Trafficking initiative or relevant working groups) to share best practices and stay at the forefront of efforts to eradicate modern slavery in technology and finance sectors.
Policy and Procedure Updates: We are updating our internal procurement procedures to include an automated flag if a potential vendor has no publicly available modern slavery statement when they should (based on size/sector). This will prompt additional due diligence or discussions before contracting. We will also consider requiring all vendors, regardless of legal obligation, to affirm our anti-slavery expectations, thereby spreading good practices even to smaller companies.
Extended Training: We will increase the depth of training for certain roles – for instance, providing advanced investigative training for compliance staff on identifying trafficking networks in financial transaction data, and enhanced training for HR on spotting any coercive practices (such as during recruitment).
Metrics for Effectiveness: We plan to develop more qualitative KPIs – like surveying employees on their understanding of modern slavery issues or assessing the culture of compliance – to complement the quantitative metrics. This will help ensure our efforts are not just procedural but truly resonating with our people.
Annual Statement Enhancement: Each year we will report on our progress and newly identified risks. The Australian Modern Slavery Act encourages setting improvement goals for the next reporting period, and we fully endorse that approach. Thus, this Statement not only recounts past actions but sets the stage for future accountability.
By committing to these future steps, TrustlessPay aims to not only remain compliant with all current laws but to proactively exceed minimum requirements and be a leader in our commitment to human rights.
Compliance with Legal and Ethical Standards
This Statement has been prepared to satisfy the requirements of the UK Modern Slavery Act 2015 (Section 54) and the Australian Modern Slavery Act 2018 (Cth), as well as to serve as our disclosure under the California Transparency in Supply Chains Act (SB 657). It addresses the major content criteria set forth in these laws, including: a description of our business and supply chain, our policies on slavery and trafficking, the due diligence and risk assessment processes we use, the parts of our business where there is risk of modern slavery and how we manage that risk, how we measure the effectiveness of our efforts, and the training provided to staff. We have striven to cover all these points in a clear and comprehensive manner, recognizing that the law encourages disclosure of all steps taken to address modern slavery.
Furthermore, we note the broader legal context: TrustlessPay also complies with all relevant U.S. federal and state laws relating to forced labor and human trafficking. The United States has increased enforcement against forced labor in supply chains in recent years, including import bans on products made with forced labor (under the Tariff Act of 1930, 19 U.S.C. §1307) and liability for companies that benefit from trafficking . California’s law, in particular, requires companies to report on their efforts in five key areas (verification of supply chains, supplier audits, supplier certifications, internal accountability, and training) – all of which are addressed in our policies and described above. While TrustlessPay is not a retail seller or manufacturer, we voluntarily uphold the spirit of SB 657 by being transparent about these efforts. Internationally, we align our practices with frameworks such as the ILO’s fundamental conventions on forced labor (ILO Conventions No. 29 and No. 105) and child labor (Conventions No. 138 and No. 182), and with the UN Universal Declaration of Human Rights, reinforcing that all people deserve freedom and dignity . Our commitment goes beyond compliance; it is about leadership in ethical business conduct.
This Statement is a reflection of TrustlessPay’s dedication to continuous improvement and accountability in the fight against modern slavery. It will be reviewed and updated annually, and we will keep reporting on our progress. We believe that through vigilance, transparency, and collaborative action, businesses can significantly contribute to ending modern slavery worldwide. TrustlessPay is determined to be part of that solution – leveraging our innovative spirit not just in technology, but also in building a more just and humane world.
Approved by the Founder and CEO of TrustlessPay Digital Assets, Inc.
Signed on behalf of the company by: Gregory David Bailey, Founder & CEO, TrustlessPay Digital Assets, Inc.
Date: August 31st, 2025
– Global Anti‑Slavery and Human Trafficking Statement will be reviewed again on August 31st, 2026 by board members for modifications, clarifications and sign off by board members.
