Human Rights, Anti-Bribery and Modern Slavery Statement
Eradicating financial crime
Neurocom and its subsidiaries are fully committed to operating responsibly and adhering to the highest ethical standards. In the financial and eCommerce sectors, GPayments provides a complete range of integrated payment and authentication products, while Member Check offers secure and comprehensive assistance to organisations in meeting their anti money laundering and counter terrorism financing obligations, through its MemberCheck and NameScan AML compliance and KYC services.
Neurocom functions to combat financial crime and has a zero-tolerance approach to corruption and slavery. Slavery, human rights violations and bribery are morally reprehensible crimes that deprive individuals of liberty and dignity. These are genuine problems that our marketplace faces and as a socially responsible organisation, we strive to incorporate respect for human rights into our practices and values, maintaining the highest standards of ethical behaviour when operating abroad and managing our supply chain.
Embedded culture of accountability
Neurocom has robust frameworks and processes in place to minimise the risk of bribery, human rights violations and modern slavery at various levels of business operation. All employees, customers and suppliers are encouraged to report any suspicion of misconduct, without fear of retaliation.
HR policies and processes ensure that all direct employees are treated fairly and in a way that safeguards their human rights. Our Executive Management is constantly monitoring employment legislation and regulations, in the countries in which we operate, in order to stay up-to-date with required policy amendments.
Educate to effect change
Neurocom has a companywide awareness program centred around global corruption and modern slavery issues. Information is transmitted to employees via email and training sessions are held that cover:
Neurocom’s commitment in the fight against corruption, human rights infringements and modern slavery, in its various forms including slavery, servitude, human trafficking, forced marriage, forced labour, debt bondage, child labour, and deceptive recruiting for labour or services, as defined in the Federal Modern Slavery Act of 2018.
- What information can be shared with suppliers and clients in relation to slavery policies and mitigating controls?
- How employees should identify and report suspicious activity?
Effective and ethical supply chains
Neurocom is a technology solution provider, where the main industry operating requirement sets the organisation away from the high-risk industries as delineated in the Commonwealth Modern Slavery Act 2018. The diverse digital authentication solutions offered by Neurocom are designed to combat financial crime, and function to aid clients in meeting their regulatory requirements. Risk assessment is conducted for our supply chain by taking into account the business operations and services rendered by suppliers. These findings then determine the mitigating controls implemented.
Extra attention for suppliers
Neurocom conducts due diligence on all new suppliers during onboarding, and on existing suppliers, at regular intervals. This includes:
- Assessing risks in the provision of particular services;
- Contracting for continual auditing of suppliers;
- Checks of supplier’s reputation, respect for the law, compliance with health, safety and environmental standards;
- Ensuring that suppliers have a system to escalate complaints internally.
We encourage all suppliers to attest that their employees work voluntarily and that they do not use any form of forced, compulsory or slave labour.
If Neurocom is made aware of any of human trafficking, slavery or corruption activities against any supplier, prompt action would be taken against the supplier and the relevant authorities would be informed.
*This Statement has not been formally submitted to the Australian Border Force.