The UK Modern Slavery Act

Pagero is committed to the UN Global Compact and believes that business is better when it is fair and done with respect for all individual’s human rights.


As per the UK Modern Slavery Act, companies are called upon to report on their practices regarding understanding and preventing any kind of human trafficking, forced or slave labor in their own operations and their supply chain. Pagero is committed to the UN Global Compact and believes that business is better when it is fair and done with respect for all individual’s human rights. In this document we present our commitments and ways of working in relation to modern slavery, which is a part of our Code of Conduct and how we do business at Pagero.

About Pagero

Pagero believes buying and selling should be easy. That’s why we’re building the world’s largest open business network so that our customers can connect with any business partner anywhere in the world.

Pagero helps companies digitize, automate, capture, and interpret data so that they can connect and engage with any business partner accurately and reliably through a single connection to our cloud-based network. We provide data accuracy, real-time visibility, and end-to-end operational excellence regardless of company size or industry.

Our value-added services enable our customers to ensure data quality, obtain 100% digital inbound and outbound business document flow, minimize error handling, facilitate spend management, and achieve and maintain compliance with local VAT/tax regulations.

Pagero is the Network for global business process automation (P2P & O2C) – 5G for Business.

Pagero Group has more than 900 employees. In addition to its headquarters in Gothenburg, Sweden, it has local offices worldwide, including London, Madrid, Chicago, and Singapore. More information about us is available in our Annual Report, available here.

Pagero Code of Conduct and Supplier Code of Conduct

Pagero follows, as a minimum, local legislation on labor rights wherever we operate and try as far as local applicable legislations allow to provide similar benefits and competitive salaries globally. These and other commitments form the foundation of our Code of Conduct, which applies to all employees and subsidiaries. The commitments are extended to all contractors and partners through our Supplier Code of Conduct which states our expectations and requirements on those we do business with.

Employees or third parties who identify a potential or actual violation of these commitments or requirements are encouraged to file an anonymous report through our whistleblowing portal, and everything reported through the portal will be subject to assessment.

Our framework

Pagero has implemented the following governing documents which address issues raised by the Modern Slavery Act:

  • Pagero Code of Conduct
  • Supplier Code of Conduct
  • Supplier and IT System Management Routine
  • Whistleblowing policy
  • Sustainability (CSR) Policy

Pagero’s supplier and due diligence in our supply chain

Our suppliers are located around the globe, including the following regions: 

  • Europe
  • Latin America
  • Middle East
  • Asia
  • North America

The services and products provided by our suppliers include:

  • North America
  • Hosting/data centers
  • Facilities
  • Software/IT systems
  • Technology/code
  • Telecommunication
  • Office services
  • Recruitment & HR services
  • Payroll & financial services
  • Marketing
  • Travel booking

Pagero has implemented a process for supplier onboarding and supplier monitoring, which is governed by our Supplier and IT System Management Routine. Both the supplier onboarding and supplier monitoring processes include the identification, assessment and handling of identified risks, and this process is also audited annually by our external auditors. We require that all suppliers we onboard adhere to and sign our Supplier Code of Conduct, which outlines our expectations on fair and ethical behaviour, including having measures to combat modern slavery and other unethical labour practices. Identified risks are followed up with the supplier and the internal supplier owner regularly, and high risks are reported to Pagero’s management.   

Other initiatives


All Pagero employees must undergo ethics and code of conduct training which includes modern slavery and human trafficking as part of their employee onboarding process, and all employees also undergo mandatory annual refresher training.


Pagero has implemented an external whistleblowing system where employees and other stakeholders can report violations of our code of conduct and other concerns. The whistleblowing system is easily accessible and we recurringly remind all employees about the tool and their possibility to report.

Upcoming initiatives

Ensuring robust processes in relation to ethical business practices is a continuous process and one we are committed to improving. In 2024, we intend to create more tangible goals related to our own efforts and our suppliers and start to measure our performance in a more consistent way.

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Sofia Arveteg

Board of Directors

Initial version

Other important information