Combating Modern Slavery

Statement on Modern Slavery and Human Trafficking

This statement is made by Payfone, Inc. (d/b/a “Prove”) and Prove Identity Ltd in accordance with Section 54(1) of the Modern Slavery Act 2015 (the “Act”) for the financial year ending December 31, 2020. For the purposes of this statement, any reference to “Prove” is a reference to both companies unless otherwise stated.

This statement sets out the steps Prove has taken or will take to ensure there is no modern slavery or human trafficking in our supply chains or in any part of our business.

Prove’s Structure, Business, and Supply Chains


Prove Identity Ltd, a United Kingdom registered company, is a direct subsidiary of Payfone, Inc. (d/b/a “Prove”), which is incorporated in Delaware and headquartered in ew York, New York.

Prove provides digital identity verification and authentication products and services to lobal businesses, non-profit organizations, and their clients and affiliates. Operating business-to-business (B2B), Prove assists clients with fraud prevention by securely verifying digital identities when clients engage with consumers online through mobile devices and applications, websites, or client call centers.

Prove’s Policies Relating to Modern Slavery and Human Trafficking

Prior to the financial year ending December 31, 2020, Prove did not meet the worldwide revenue threshold to trigger the Act’s reporting obligations. As such, our policies and procedures addressing modern slavery and human trafficking are in their infancy.

Prove adheres to a Corporate Code of Conduct, which requires (among other things) that all employees, temporary personnel, consultants, and independent contractors to conduct their business in strict compliance with all applicable laws and regulations.

Prove’s employees acknowledge the Corporate Code of Conduct annually. Anyone who suspects or becomes aware of possible violations of Prove’s Corporate Code of Conduct(as discussed above) is instructed to notify his or her manager, a company officer, or a human resources representative.

Prove’s Compliance With Modern Slavery and Human Trafficking Policies

Prove operates in a relatively low risk industry for modern slavery and human trafficking.  However, we understand the importance of guarding against modern slavery and human  trafficking in our supply chains or in any part of our business. This includes risk-based,  thorough due diligence, monitoring, and training of our clients, vendors, and employees.

Our Clients 

High-risk prospective clients undergo detailed initial risk assessments and are  independently reviewed by our Compliance Department. This review includes identity verification, prospect due diligence, and a review of publicly available information.

Existing clients are periodically audited on an ongoing basis using a risk-based approach.

Our Vendors

Prove understands the importance of working with reputable suppliers and subcontractors  that comply with all regulatory, legal, and third-party requirements. To this end, Prove has  a Vendor Risk Management (VRM) and company-wide policy and program in place to  effectively manage our third-party vendors. The goal of the program is to gain a thorough  understanding of risks created by vendor relationships through thorough and diligent selection of available vendors and ongoing monitoring of vendor performance against  business, contractual, regulatory, and legal requirements. Specifically, Prove examines  various factors, which may include:


Prove uses a risk-based approach to regularly monitor its vendors in real-time or on an  ad hoc basis based on the nature and scope of the services provided. This ongoing diligence is performed so Prove can exercise the control necessary to properly manage its products and services. 
 
Prove will continue to assess supply chain risks and expand our due diligence and  monitoring accordingly.

Our Employees 

Prove personnel, including employees, contractors, and other short-term staff, are expected to abide by our Corporate Code of Conduct (as discussed above). Prove is an equal opportunity employer and is free of discrimination of all types. We are committed to an environment that is free from abusive, offensive, or harassing behavior. 

Prove recruits employees in accordance with established company standards. All offers of employment are contingent upon clear results of a thorough background check covering identity verification, review of criminal history, and searches of more than 30  sources including the Office of Foreign Asset Control, Office of Inspector General, United Nations Consolidated Sanctions List, European Union Terrorism List, and World Bank Debarred Parties. All Prove employees are employed by mutual agreement through a written contract governed by local law and terminable by either party. 

Prove develops and updates training for all new and existing employees on an ongoing basis and endeavors to include modern slavery and human trafficking training and awareness as appropriate. 

Board Approval 

This statement was approved by Prove’s Board of Directors on February 11, 2021.

Tom FitzSimmons 
CFO