Modern Slavery and Human Trafficking Policy

1. Our Commitment

SwiftNinePay does not tolerate forced labour, human trafficking, child labour, or any other form of modern slavery in our operations or in the supply chain that supports them.

We source and fulfil physical goods for e-commerce merchants, which means the working conditions of people we never employ directly still sit within our responsibility. This policy sets out what we expect, how we verify it, and what happens when something falls short.

It binds everyone working for or with SwiftNinePay. That covers our own employees and contractors in Sharjah, and it extends to suppliers, logistics providers, customs agents, and any other partner involved in producing or moving goods on behalf of the merchants we serve.

2. Legal Framework

SwiftNinePay operates from the United Arab Emirates and sources from Asia into European and Asian consumer markets. Our approach is built to meet the requirements that follow from that footprint, including the labour laws of each jurisdiction in which our suppliers operate.

Where local law and this policy differ, we apply whichever standard offers greater protection to workers.

3. Supplier Standards

We expect suppliers and business partners to:

• prohibit forced, bonded, or involuntary labour
• prohibit unlawful child labour
• comply with applicable employment and wage laws
• pay wages directly to workers and on time
• provide safe and lawful working conditions
• avoid practices that restrict workers' freedom of movement or unlawfully retain identity documents
• refrain from charging recruitment fees to workers
• treat workers fairly and without exploitation
• maintain records of working hours, wages, contracts, and age verification
• cooperate with reasonable requests for information relating to labour practices.

4. Supplier Code of Conduct

The standards in Section 4 are set out in full in the SwiftNinePay Supplier Code of Conduct.

Suppliers are required to sign the Code before their live-order trial begins, and to re-confirm it when the commercial relationship is renewed. A supplier who declines to sign does not proceed.

Suppliers must apply equivalent standards to any subcontractor they use, and must inform us when work is subcontracted.

5. Verification and Audit

Signing a code of conduct proves little on its own, so we reserve the right to verify.

SwiftNinePay, or a third party acting on our behalf, may audit or inspect a supplier's facilities, employment records, wage records, and working practices. Suppliers agree to permit this as a condition of working with us.

Audits may be announced or unannounced. Refusing or obstructing an audit, or presenting falsified records, is treated as a serious breach of this policy.

6. Risk Review

Modern slavery risk varies by country, industry, product category, supplier, and stage of the supply chain.

Where we identify a higher level of risk, we may request additional information, supporting documentation, or clarification before continuing or increasing business activity with a supplier. We may also raise the audit frequency for that relationship.

Supplier relationships are reviewed as operations grow and circumstances change.

7. Training

Employees involved in sourcing, fulfillment, supplier management, and operations receive training on recognising indicators of forced labour and on what to do when they see one.

Training is provided when someone joins a relevant role and refreshed annually. Records of completion are kept.

8. Reporting Concerns

Anyone can raise a concern under this policy. That includes our employees, our suppliers and their workers, logistics partners, merchants, and members of the public.

Concerns can be reported to info@swiftnine.com

Reports are reviewed and handled with appropriate confidentiality. SwiftNinePay will not retaliate against anyone who raises a concern in good faith, and we expect our suppliers to hold to the same rule.

9. Responding to Concerns

Where a credible concern is raised, SwiftNinePay may investigate the matter directly or request information from the relevant supplier or business partner.

Depending on the circumstances, action may include:

• requesting corrective measures within a defined timeframe
• increasing monitoring or audit frequency
• restricting new orders or activity
• suspending the relationship
• ending the relationship where serious violations are identified.

Where workers have been harmed, remediation for those workers takes priority over exiting the supplier, since an abrupt exit can leave affected workers worse off. We will end the relationship where a supplier refuses to remediate.

Matters may be referred to the appropriate authorities where required.

10. Responsibility

Responsibility for maintaining this policy sits with SwiftNinePay management, led by the Chief Operating Officer.

Employees responsible for sourcing, fulfillment, or supplier management are expected to raise concerns where they identify conduct inconsistent with this policy. Doing so is part of the role.

11. Review and Approval

This policy was approved by the SwiftNinePay leadership team and is reviewed annually.

It will also be reviewed outside that cycle where changes to our operations, supplier network, markets, or applicable law make an earlier update necessary.

12. Contact

Questions about this policy, or concerns relating to labour practices within our operations or supply chain, can be sent to SwiftNinePay at info@swiftnine.com