February 20, 2025
Human trafficking is a violation of human rights and a significant global issue that affects millions of individuals, including men, women, and children, who are exploited for forced labour, sexual exploitation, and other forms of modern slavery. As a financial institution, Paxum Bank Limited recognizes the financial sector's critical role in detecting, preventing, and disrupting financial flows linked to human trafficking.
Paxum Bank Limited is committed to combatting human trafficking in all forms. Our policies, procedures, and compliance frameworks are designed to identify, prevent, and mitigate the risks associated with transactions that could facilitate or be linked to such exploitation. We hold ourselves and our business partners to the highest ethical and legal standards and take an uncompromising stance against financial crime, including human trafficking and forced labour.
This statement outlines our commitments, policies, preventive measures, and reporting mechanisms as part of our ongoing efforts to combat human trafficking and modern slavery.
Human trafficking is a crime and a violation of fundamental human rights that involves the exploitation of individuals for labour or sexual purposes through force, fraud, or coercion. It is a global issue that affects both adults and children, with perpetrators profiting from the manipulation and abuse of vulnerable persons.
Human trafficking occurs when an individual or organization recruits, transports, transfers, harbours, or receives persons for the purpose of exploitation, using means that include deception, physical force, psychological control, abuse of power, threats, or financial coercion.
Paxum Bank Limited recognizes that financial institutions play a critical role in detecting and preventing financial flows linked to human trafficking. As part of our commitment to combatting this crime, we adopt a zero-tolerance approach to facilitating or enabling any form of human trafficking, directly or indirectly.
Human trafficking generally falls into two primary categories:
Paxum Bank Limited acknowledges that all cases involving children in commercial sexual activities constitute human trafficking, regardless of whether force, fraud, or coercion was involved.
The internationally accepted definition of human trafficking consists of three core elements:
All three elements must be present for a case to be classified as human trafficking under legal and regulatory frameworks, except in cases involving child sexual exploitation, where the means element is not required.
2.3.1 Definition of Forced Labor
Forced labour, also known as labour trafficking, occurs when individuals are compelled to work against their will through force, fraud, or coercion. Traffickers exploit victims in a variety of industries, often depriving them of their freedom and financial independence.
Forced labour can be present in legitimate businesses, supply chains, and illicit operations. It may occur in agriculture, construction, hospitality, manufacturing, mining, domestic work, fishing, and other sectors where oversight and regulation are weak.
2.3.2 Indicators of Forced Labor
Key indicators of forced labour include:
2.3.3 Domestic Servitude
One particularly hidden form of forced labour is domestic servitude, in which victims are exploited within private households. The nature of this crime makes it difficult to detect, as victims are often isolated, hidden from public view, and denied access to outside assistance.
2.3.4 Forced Child Labor
Forced child labour involves the coerced or involuntary exploitation of children in labour activities. While not all child labour is classified as trafficking, children subjected to forced labour, bonded labour, or hazardous working conditions under threat or deception are considered victims of trafficking.
2.4.1 Definition of Sex Trafficking
Sex trafficking occurs when traffickers use force, fraud, or coercion to compel individuals into commercial sex acts for financial gain. This crime can take place in brothels, massage parlours, hotels, private residences, and online platforms and may involve both physical and psychological coercion.
Sex trafficking is particularly difficult to detect, as traffickers often:
Use threats, violence, or drug dependency to maintain control over victims.
Exploit economic vulnerabilities, homelessness, or migration status.
Restrict movement and isolate victims from external assistance.
2.4.2 Child Sex Trafficking
Any commercial sexual exploitation of a child under the age of 18 is classified as human trafficking, regardless of whether force, fraud, or coercion was involved. Children are particularly vulnerable to trafficking through false job offers, social media manipulation, and familial exploitation.
2.5.1 Consent is Irrelevant in Human Trafficking
A victim’s initial consent to labour or commercial sex does not negate the existence of trafficking if force, fraud, or coercion is later introduced. Traffickers often manipulate victims after they have initially agreed to a job or arrangement, gradually increasing control and exploitation.
2.5.2 Human Trafficking Does Not Require Movement
Contrary to popular belief, human trafficking does not require cross-border transportation. Victims may be trafficked within their own country, region, or city, with exploitation occurring in familiar environments. The defining factor is exploitation, not transportation.
2.5.3 Debt Bondage as a Method of Control
Debt bondage is a key form of coercion used by traffickers, where victims are forced to work off a never-ending debt under exploitative conditions. Victims are often charged for housing, food, and travel expenses, creating an artificially inflated debt they can never escape.
2.5.4 The Non-Punishment Principle
Victims of human trafficking should not be criminalized for unlawful acts they were forced to commit under duress. Recognizing the trauma and coercion experienced by trafficking victims is essential in ensuring proper victim protection and support.
2.5.5 State-Sponsored Human Traffickin
In some cases, governments or state-affiliated actors engage in or facilitate human trafficking, including:
Paxum Bank Limited maintains a strict prohibition against engaging with entities involved in state-sponsored trafficking and incorporates enhanced due diligence measures when assessing such risks.
Forced labour and human trafficking are well-documented in specific industries, particularly those with complex supply chains, informal labour arrangements, or opaque financial transactions. The financial sector is crucial in identifying and disrupting illicit financial flows linked to trafficking.
Paxum Bank Limited is committed to preventing financial transactions linked to human trafficking through:
Paxum Bank Limited will terminate relationships with customers, vendors, or business partners found to be involved in human trafficking and will report such activities to the appropriate authorities.
Paxum Bank Limited upholds and aligns its policies with internationally recognized human rights and anti-financial crime frameworks, including but not limited to:
Our policies reflect these frameworks and are continuously reviewed and updated to adapt to evolving risks, regulatory changes, and best practices in combatting financial crime.
Paxum Bank Limited employs a risk-based approach (RBA) to identify, mitigate, and manage risks associated with financial transactions linked to human trafficking. Our Compliance and Risk teams are dedicated to ensuring that our Know Your Customer (KYC), Customer Due Diligence (CDD), and Enhanced Due Diligence (EDD) processes are designed to prevent financial abuse by illicit actors involved in human trafficking.
6.1 Customer and Business Partner Due Diligence
Our due diligence framework ensures that we do not knowingly provide financial services to individuals, entities, or organizations involved in human trafficking, forced labour, or other human rights abuses. Key due diligence measures include:
6.2 Transaction Monitoring and Suspicious Activity Identification
We deploy advanced systems to detect potential financial transactions linked to human trafficking.
We believe that awareness and education are fundamental to combatting human trafficking within the financial system. Paxum Bank Limited mandates annual anti-human trafficking and financial crime training for all employees, ensuring that our staff is equipped with the knowledge to:
Additionally, we provide targeted training sessions for all departments to ensure specialized personnel are adequately trained to handle human trafficking-related concerns effectively.
Paxum Bank Limited maintains a zero-tolerance policy toward human trafficking, forced labour, and modern slavery. This applies not only to our direct financial services but also to our business relationships, vendors, and third-party partnerships. We actively assess and monitor third-party providers, including correspondent banks, payment processors, and other financial partners, to ensure they align with our ethical and compliance standards in combatting financial crime. Any entity found to be engaging in or facilitating human trafficking-related activities will face immediate** termination of services and reporting to the appropriate authorities**.
Paxum Bank Limited encourages all employees, customers, vendors, and third parties to report concerns related to human trafficking and financial crime. We maintain a whistleblowing hotline for internal and external individuals to facilitate safe and confidential reporting.
Complete the whistleblowing form here
All reports are treated with strict confidentiality, and we do not tolerate retaliation against individuals who report in good faith. Our Compliance Department will promptly review reports, taking appropriate action where necessary.