YaYa Digital Ltd.

Modern Slavery and Human Trafficking Statement for the Financial Year Ending 30 April 2022

Introduction 

This statement sets out the steps taken by Yaya Digital Limited (“Yaya”) to ensure that slavery and human trafficking are not taking place in our supply chains or in any part of our business. Slavery and human trafficking can occur in many forms, such as forced labour, child labour, domestic servitude, sex trafficking and workplace abuse.

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Given the nature of the work that we do, we believe that there is a low risk of slavery or human trafficking having any connection with our business. We must, however, not be complacent, and all staff have a responsibility to be aware of any risks in our business and in our wider supply chains, no matter how remote the possibility, and report any concerns to senior management. 

Our supply chains Our supply chains comprise primarily services, including professional advisory services. 

We have reviewed our supply chains and believe the overall risk of modern slavery is low owing to:

• The nature of the goods and services which we procure (mostly skilled professional services); The locations from which we procure it (in developed markets); 
• Our procurement practices (for example, we agree to reasonable terms and ensure timely payment). 
  

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Our policies on slavery and human trafficking 

We have a zero-tolerance approach to modern slavery and human trafficking, and we are fully committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We believe in paying people fairly and properly for their work. This policy and our internal policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. 

Due diligence processes for slavery and human trafficking 

As part of our initiative to identify and mitigate risk we have in place systems to:

• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.

We set clear expectations for our suppliers by informing them that Yaya does not tolerate modern slavery or any form of human trafficking within its business or supply chains and that Yaya does not allow harsh or inhumane treatment and we expect our suppliers to share our values.

• Monitor potential risk areas in our supply chains.
• Staff are encouraged to report any concerns to senior management.
• Ensure appropriate recruitment practices are carried out.

We verify the practices of any new recruitment agency as part of our terms of business with them and before accepting any workers from that agency.

• Protect whistle blowers. At Yaya, workers are encouraged to report any concerns related to our activities or supply chains.
• Supplier adherence to our values We require that all contractual agreements with third party suppliers to contain obligations to ensure compliance with the Modern Slavery Act 2015. As part of any due diligence exercise during supplier on boarding or at regular intervals, potential slavery concerns must be assessed and addressed.
• Training 

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we will be providing training to appropriate members of staff. 

Our commitment 

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Yaya’s slavery and human trafficking statement for the financial year ending 30 April 2022. Following its initial adoption, this Modern Slavery and Human Trafficking Statement will be reviewed by Yaya’s Board of Directors at least annually and may be amended from time to time.