Legal

Modern Slavery Statement

Slavery, servitude, forced labor and human trafficking have no place in our business or our supply chain. This is what we do to keep it that way.

Approved October 8, 2026 Reviewed every year Version 1.1

1. About this statement

This statement is made by Tuppence AI Ltd, which operates Tuppence, and sets out the steps we take to prevent modern slavery and human trafficking in our business and our supply chain.

Section 54 of the UK Modern Slavery Act 2015 requires a statement from businesses with an annual turnover of £36 million or more. Our turnover is well below that, so we are not required to publish one. We publish it voluntarily, because the businesses that rely on us should know how we work, and because the right time to build these habits is while we are small.

2. Our business

Tuppence AI Ltd is a private limited company registered in England and Wales, with its registered office in London. We build and run Tuppence, a software platform that lets businesses in the United Kingdom and the United States take card payments, bill for usage, run AI agents and spend with business cards. The regulated payment services are provided by our payment partner, Stripe.

We are a small team: our director, supported by skilled contractors, mostly software engineers, who work remotely. We sell no physical goods and run no factories, warehouses or shops.

3. Our supply chain

What we buy is almost entirely services, from a short list of suppliers:

  • Cloud hosting and infrastructure: Google Cloud (hosting, databases and storage, in London) and Cloudflare (network and security);
  • Payment partners: Stripe, which processes card payments and pays out to businesses, and the card networks and banks it works with;
  • Software services: email delivery (Resend), push notifications (Expo), text messaging (Twilio), AI models (Anthropic), team messaging (Slack), code hosting (GitHub) and similar tools;
  • Contractors and professional advisers: individual software engineers and designers, and accountants and lawyers;
  • Physical goods: a small number of laptops and other equipment from established retailers, and the physical Tuppence cards that our card issuers have produced for cardholders who order them.

4. Our policies

This statement sits alongside our Anti-Bribery and Corruption Policy, our Whistleblowing Policy and our Acceptable Use Policy. Together they set out our aims to:

  • pay everyone who works for us fairly and on time, in line with the law where they work, and never below the applicable minimum wage;
  • agree terms in writing with every contractor before work starts, never hold anyone’s identity documents, and never charge anyone a fee to work for us;
  • let anyone raise a concern, confidentially, without fear of retaliation;
  • refuse to provide payment services to any business involved in slavery, forced labor, human trafficking or the sexual exploitation of anyone.

5. Where the risks are

We consider the risk of modern slavery in our own operations to be low: our team is small and highly skilled, and works directly for us on written terms. The risks in our supply chain sit mainly further up it, where we have least visibility:

  • Hardware manufacturing: the servers our cloud providers run on, and the laptops and phones we use, are made in global electronics supply chains where forced labor has been found, including in mineral extraction and component assembly;
  • Outsourced services: cleaning, security and construction at data centers run by our suppliers;
  • Card production: the manufacture of physical payment cards by our card issuer’s suppliers.

We also recognize that a payments platform could be misused to take payments for businesses that exploit people. We treat that as a risk in its own right (section 7).

6. Due diligence

  • We choose large, established suppliers that publish their own modern slavery statements and supplier codes of conduct. Google, Stripe and Cloudflare each publish a modern slavery statement, and we aim to read them when we take a supplier on and when they are renewed.
  • Before we take on a new supplier that is not a large, established company, we aim to check who they are and how they work, and to include a clause in the contract requiring them to comply with modern slavery law.
  • We engage contractors directly, on written terms, and pay them directly. We do not use labor agencies or recruitment intermediaries.
  • We would expect to stop working with any supplier that we find has used forced labor and will not put it right.

7. Our customers

Every business that takes live payments through Tuppence is verified before its first payout: we check who owns and controls it, and a person reviews it. Our Acceptable Use Policy prohibits illegal products and services and the adult services where exploitation is most common, and we monitor payments for signs of misuse. If we suspect that a business is involved in modern slavery or human trafficking, we may close its account and report it to the police and the relevant authorities.

8. Training and reporting

Everyone who works on Tuppence reads this statement and our Whistleblowing Policy when they join, and our onboarding reviewers are briefed on the signs of exploitation in a business’s activity. Anyone, inside or outside Tuppence, can report a concern to contact@tuppence.ai. If you think someone is in immediate danger, call 911. You can also contact the National Human Trafficking Hotline on 1-888-373-7888.

9. Next steps

Over the year this statement covers, we intend to:

  • keep a written register of our suppliers, with the date we last reviewed each one;
  • add a modern slavery clause to our standard contractor and supplier terms;
  • review this statement every year, and publish an updated one, approved by our director.

10. Approval

This statement was approved by the director of Tuppence AI Ltd on October 8, 2026.

11. About this statement

We publish this statement voluntarily, for information. It describes our approach and our intentions; it is not a contract, does not form part of our Terms of Service or any other agreement, and gives no promise, warranty or guarantee to anyone, including about our suppliers, whose own practices we do not control. We may change it at any time.