Modern Slavery and Human Trafficking Statement

This is the statement of steps that PAA CAPITAL (PTY) Ltd, its subsidiaries and affiliated companies (“PAA”) has taken to ensure that slavery and human trafficking are not taking place in our business or in our supply chains.  This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) and constitutes our Modern Slavery and Human Trafficking Statement for the financial year ending 31 December 2017.

PAA are responsible employers and seek to ensure that the behaviours and practices of our suppliers reflect our own business standards and compliance with applicable laws and standards. We take a zero-tolerance stance on slavery and human trafficking within our workforce and expect the same from our supply chain.

The Group

PAA is a focused financial services company providing a range of financial solutions including full platform services, administration and independent financial advice. PAA is registered in 18 countries, spread over four continents.

PAA is not listed publicly and solely privately held.

Our Supply Chains

PAA does not act as a producer, manufacturer or retailer of any physical goods. As a provider of financial services, we do not have a very long or complex supply chain. Our main suppliers are mainly providers of office supplies and support services which based worldwide. While we consider our suppliers to be at relative low risk of engaging in practices of modern slavery and human trafficking, we remain committed to preventing the occurrence of any such practices in both our business and our supply chain.

Our Policies and Principles in relation to Slavery and Human Trafficking:

As part of our commitment and obligations under the Modern Slavery Act and other legislation relating to the detection and prevention of modern slavery, we have an Anti-Slavery Policy which reflects our commitment to act ethically and with integrity in all our business relationships.

We have an Outsourcing and Service Provider Policy, which requests managers to carry out due diligence and a risk assessment prior to entering into a contract with outsourcing and service providers including the assessment to adherence to the requirements of the Act and its reporting thereon.

PAA has a whistleblowing procedure in place and we conduct annual employee engagement surveys for our employing subsidiaries, both of which are opportunities for employees to raise their concerns regarding any wrong doing or breaches of law, which they can raise in confidence.

We ensure that there is transparency in both our supply chains and our own business, and expect the same standards from our contractors, suppliers and other business partners. We continue to be committed to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking is not taking place in our supply chains.

What we are doing to prevent slavery and human trafficking


PAA undertook on a proportionate basis a risk assessment of our current suppliers to identify any areas where there may be a potential risk of modern slavery and human trafficking.  We considered both the sector and the jurisdiction in which our suppliers operate.

One of the risks for a financial institution such as PAA is that it may be involved in facilitating financing from or supporting cases of modern slavery through money laundering. PAA has a Financial Crime Framework, an Anti-Bribery Policy and a Money Laundering Reporting Officer in place. As our main subsidiaries are financial-regulated, we are very strict in identifying and preventing any form of money laundering including any laundering that may facilitate financing that supports modern slavery.

The results of our risk assessment found that our suppliers presented a very low risk of modern slavery or human trafficking in our supply chain.


In order to mitigate the risk of modern slavery and human trafficking in our supply chain, all new PAA suppliers have to go through due diligence and a risk assessment, as set out in our Outsourcing and Service Provider Policy. In order to ensure compliance with this policy, our Risk and Compliance team will carry out an annual review of our supplier management process and the adherence to the Outsourcing and Service Provider Policy, the first of which will occur in the course of 2018.

We are in the process of reviewing our contractual arrangements with existing suppliers to include a new provision requiring suppliers to comply with the Modern Slavery Act, as well as to warrant that their suppliers are in full compliance with the Modern Slavery Act.   Additionally, we will ensure that all new supplier contracts will also incorporate similar terms.


We have robust HR policies and practices that align with our obligations under the Act; PAA ensures appropriate background checking procedures are undertaken on all new joiners and apply equally to permanent employees, as well contractors. We have not found any evidence to suggest that modern slavery is present within our business.  Although we have assessed that we are at very low risk in this regard, we remain alert to possible risks of modern slavery and we will continue to adhere to our HR policies and commitment to zero-tolerance for this risk.

While we continue to develop our approach to the prevention of modern slavery and human trafficking during the course of 2018 we will continue to assess and manage risks on an on-going basis. Our aim is to apply the same ethical standards to our employees and our suppliers with transparency and accountability.

Approved by the Board on 17 January 2018.

Cem Wald