The NeoBankers Group Limited

The financial infrastructure of the next decade will not be built on legacy systems

The Group is building it.

Financial & Technology Holding Group — Pioneering the Integrated Digital Financial Ecosystem

Fintech · Payments · Blockchain · Digital Assets · IT & Technology · Regulatory Advisory

Our Company

About The NeoBankers Group

The NeoBankers Group is an independent, international holding group based in the United Kingdom, whose founding team combines over 25 years of experience in fintech, private advisory, blockchain infrastructure, and regulatory services.

The Company holds equity interests in its subsidiaries, intellectual property, and registered trade marks.

The Group owns and develops digital financial infrastructure spanning regulated payments, digital asset services, collateralised lending, and real-world asset tokenisation, with embedded insurance in development as a fifth sector.

Through its operating subsidiaries, the Group serves consumers, small businesses, corporations, and institutional partners. The holding company designs the architecture, funds the operations, and maintains the regulatory framework within which each entity operates.

The Group is building an Integrated Digital Financial Ecosystem (IDFE) — a unified platform architecture that has no direct analogue on the market today. IDFE belongs to a category only now taking shape in the financial services industry, one for which no established term yet exists. It brings together classical payment instruments, blockchain-based transactions, platform-as-a-service infrastructure, and a token economy within a single seamless environment.

Company No.
13821747
Incorporated
England & Wales
Since
30 December 2021

Innovation is not an ancillary feature. It is a foundational methodology.

The Group develops products and technologies that remove friction from financial transactions — whether conventional payments or blockchain. Every process that can be automated should be automated. Every step that can be eliminated should be eliminated.

The focus is accessibility. Digital financial services should be available to all — designed to be intuitive and inherently resilient. Convenience and a high standard of security are not mutually exclusive. That is the standard.

The Group's approach is architectural rather than product-led, reflected in a single transaction platform that bridges fiat and digital assets, designed from the ground up for speed, reliability, and institutional trust.

The Group's culture rests on six core values that inform its decisions.

Put Clients First
The client's interest is the starting point for every product and every service the Group delivers.
Do the Right Thing
Integrity in every interaction. We say what we do and do what we say.
Lead with Exceptional Ideas
Innovation is not optional. We develop new solutions; we do not replicate what exists.
Diversity & Inclusion
Financial services designed to be accessible to the widest possible number of people. Fewer barriers, less complexity, broader inclusion.
Give Back
The Group seeks to create value beyond its commercial operations — through accessible infrastructure, transparent governance, and contributions to the frameworks that protect all market participants.
Security
Safety is not subordinated to ease of use. A high standard of protection is the norm, not the exception.
  • The Company is governed by its Board of Directors in accordance with the Companies Act 2006.
  • Directors owe their duties to the Company and act to promote its success for the benefit of members, having regard to stakeholders including employees, partners, and the wider community.
  • Regulated activities are carried on by the Group's operating subsidiaries, not by the Company.
  • Related-party relationships and transactions are disclosed in accordance with applicable accounting standards. Such disclosures are reviewed by the Board.
  • The Company publishes its accounts and filings with Companies House as required by law.
  • The Group's intellectual property and trade marks are held and protected at holding company level.

The Group does not fit into an existing category. It is creating one.

The Integrated Digital Financial Ecosystem is not an improvement on what exists — it is an architecture for what comes next. A single environment where traditional and digital financial instruments operate as one. Where automation replaces manual processes at each level. Where accessibility and security are not in tension with each other but are mutually reinforcing.

There is no established term for what the Group is building because the market has not yet seen it built. The Group is among the pioneers shaping this category.

The Group holds itself to institutional standards — in the quality of its technology, the rigour of its regulatory framework, and the clarity of its governance. That standard is not aspirational. It is integral to how the Group operates.

The conviction is simple: financial services must work for all, without compromise on safety. That is the standard the Group sets for every product and technology it develops.

Our Philanthropy

Philanthropy and ESG Integration

“For the world you may be just one person, but for one person you may be the whole world.”

Gabriel García Márquez

Accessibility is not incidental to what the Group builds. It is embedded in how it builds.

The Group was founded on the conviction that digital financial services should be available to underserved and excluded populations worldwide — securely and without unnecessary complexity. This conviction informs the Group’s product architecture, jurisdictional strategy, and technology design. The Group endeavours to contribute to financial inclusion not through philanthropy alone, but through the commercial infrastructure it develops and the regulatory standards to which it holds itself.

Financial Inclusion
Broadening Access

An estimated 1.4 billion adults worldwide lack access to formal financial services (World Bank Global Findex, 2021). The Group’s product architecture is designed from the outset to serve individuals and communities for whom traditional banking channels remain inaccessible or prohibitively expensive. Each regulated licence the Group obtains is intended to extend the reach of that infrastructure — creating new points of entry, not new barriers.

Financial Literacy
Transparency & Plain Language

It is the Group’s policy to maintain transparent fee structures and clear client communications. The Group’s practice is to publish product documentation, risk disclosures, and governance frameworks in plain language. In-app educational content is designed to help clients understand financial products, blockchain technology, and the risks associated with digital assets — enabling informed decision-making.

Sustainability
ESG Integration

The Group’s approach to environmental, social, and governance matters is informed by UN Sustainable Development Goals 1 (No Poverty), 8 (Decent Work and Economic Growth), 9 (Industry, Innovation and Infrastructure), 10 (Reduced Inequalities), and 16 (Peace, Justice and Strong Institutions). The Group publishes a Modern Slavery Statement voluntarily and maintains a zero-tolerance anti-bribery policy under the UK Bribery Act 2010. Supplier due diligence is conducted on a risk-proportionate basis.

“We do not presume to solve financial exclusion. We seek to build infrastructure that makes inclusion easier — and to hold ourselves to the standards that make it trustworthy.”
Matvei Hutman
Group CEO · Executive Director
Our Businesses

Our Businesses

These services are provided by the Group's operating subsidiaries and selected partners. The Company does not itself conduct regulated financial services activity or provide services directly to end clients.

Payments
E-money solutions, multi-currency accounts, SEPA, SWIFT, card programmes
Digital Assets
Digital asset custody, digital asset exchange, OTC desk, tokenisation services, blockchain infrastructure
BaaS
White-label infrastructure, embedded finance APIs, compliance-as-a-service
Token Economy
Electronic money tokens (MiCA), RWA tokenisation, collateralised digital lending
IT & Technology
Software development, platform engineering, system architecture, IT consulting
Licensing & Regulatory Advisory
Regulatory strategy, compliance framework design, licensing pathway consulting, jurisdictional analysis
Management Consulting
Strategic advisory, corporate structuring, capital-raising support, M&A transaction advisory, regulatory and licensing strategy, and cross-jurisdictional compliance consulting
Business Development
Institutional relationship management, strategic partnership origination, network access across regulated financial services, counterparty introductions
Mergers & Acquisitions
Corporate expansion advisory, reorganisation strategy, transaction structuring, independent deal-execution support
Our Portfolio

Portfolio and Corporate Structure

Details of the Group’s corporate structure and regulatory portfolio are available to qualified investors upon execution of a Non-Disclosure Agreement.

Request Access
Leadership Team

Leadership Team

Dr Reinis Tumovs
Group Executive Chairman
Founder & Principal
Matvei Hutman
Matvei Hutman
Group CEO · Executive Director
Co-Owner & Co-Principal
Vladimir Vardzielov
Vladimir Vardzielov
Group CFO · Executive Director
Co-Owner
Jacob Mitbreit
Jacob Mitbreit
Group COO
Co-Owner
From the Chairman

Statement from the Chairman

"We set out to build something that does not yet exist on the market — an Integrated Digital Financial Ecosystem where classical payments and blockchain transactions coexist within a single, integrated architecture. We believe this is the future of financial services, and we are building it with the discipline and rigour that institutional partners and regulators expect."

Dr Reinis Tumovs
Founder & Executive Chairman
Insights

Insights and Perspectives

Thesis · April 2026
IDFE: A Category Without a Name

The Integrated Digital Financial Ecosystem belongs to a market segment that is only now taking shape. No established term yet exists for a regulated platform architecture that unifies fiat payments, digital asset custody, collateralised lending, RWA tokenisation, and an embedded token economy within a single compliance framework. The absence of a name does not indicate the absence of a market — it indicates that the category is being defined by those building it. This paper examines the structural, regulatory, and economic foundations of the IDFE model, and considers why existing labels — neobank, exchange, payments company — fail to capture the architecture the Group is constructing.

Financial Infrastructure · MiCA · TVTG
Perspective · March 2026
The Convergence of Payments and Blockchain

Classical payment instruments and distributed ledger transactions are converging toward a single infrastructure layer. The trajectory is visible in the regulatory direction set by MiCA in the European Union, the FCA's evolving approach in the United Kingdom, and the increasing institutional adoption of tokenised settlement. The remaining questions are pace and governance. This perspective examines the technical, regulatory, and commercial drivers of convergence, and assesses what it means for firms building at the intersection of traditional payment rails and blockchain-native architecture. The Group’s thesis is that the winners in this convergence will be those who hold both payment licences and digital asset authorisations within a single group structure.

Payments · Blockchain · Regulation
View · February 2026
Automation as Prerequisite, Not Feature

Every manual step in a financial transaction is a point of failure, a source of cost, and a barrier to scale. The next generation of financial services infrastructure will automate by default — not as a competitive advantage, but as a baseline requirement. This view examines how the Group approaches automation across its platform: from KYC onboarding and transaction monitoring to regulatory reporting and compliance controls. The argument is not that automation improves financial services. It is that manual processes in financial services are no longer economically or operationally viable at the scale the industry demands. The Group’s proprietary technology kernel is designed from first principles to eliminate human intervention from every process where it adds friction without adding value.

Technology · Automation · FinOS

IMPORTANT NOTICE — By accessing and using this website, you acknowledge that you have read, understood, and agree to be bound by this notice. This website is published by The NeoBankers Group Limited, a private limited company incorporated in England & Wales (Company No. 13821747). The Company is a holding company and does not itself conduct regulated financial services activity. The Company is not a bank, a credit institution, an investment fund, or an investment firm. The Company is not authorised or regulated by the Financial Conduct Authority or the Prudential Regulation Authority. This website does not constitute a financial promotion within the meaning of Section 21 of the Financial Services and Markets Act 2000 (FSMA). Nothing on this website constitutes investment advice, a recommendation, an investment offer, an invitation to invest, a solicitation of any kind, or an offer to sell or buy any security, financial instrument, or service. No reliance should be placed on any information on this website for the purpose of making any investment or business decision. This website may contain forward-looking statements that reflect the Group's current expectations regarding future events and business development. Such statements involve known and unknown risks, uncertainties, and other factors which may cause actual results to differ materially from those expressed or implied. The Company undertakes no obligation to update or revise forward-looking statements. Information on this website is subject to change without notice. This website is governed by the laws of England & Wales. Any dispute arising from or in connection with the use of this website shall be subject to the exclusive jurisdiction of the courts of England and Wales. This website is not directed at US Persons (as defined in Regulation S under the US Securities Act of 1933), nor at any person in a jurisdiction where its publication or availability would contravene local laws or regulations, nor at any person or entity subject to sanctions or restrictive measures imposed by the United Kingdom (OFSI), the European Union, or the United States (OFAC). Data protection: the Company processes personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. For details, see our Privacy Policy.

← Back The Neobankers Group
The Neobankers Group Limited
Company No. 13821747 · 167-169 Great Portland Street, 5th Floor, London, W1W 5PF
March 2026 · Version 1.0 · Adopted by the Board · Next review: March 2027

167-169 Great Portland Street, 5th Floor, London, W1W 5PF, United

Kingdom

Version 1.0 \| Adopted by the Board \| Effective \| Next

review: March 2027

Privacy & Cookie Policy

UK GDPR, Data Protection Act 2018, and PECR compliance

PART A –- PRIVACY POLICY

1. Data Controller

The data controller is The Neobankers Group Limited, Company No.

13821747, registered at 167-169 Great Portland Street, 5th Floor,

London, W1W 5PF, United Kingdom. Data protection enquiries:

dpo@theNeobankers.group.

2. Legal Framework

This Privacy Policy is issued in compliance with the UK General Data

Protection Regulation (UK GDPR) as retained by the European Union

(Withdrawal) Act 2018, the Data Protection Act 2018 (DPA 2018), and the

Privacy and Electronic Communications (EC Directive) Regulations 2003

(SI 2003/2426) (PECR).

3. Data We Collect

We may collect and process the following categories of personal data:

system, platform, time zone setting, and other technology on the

devices you use to access this website.

referral source, length of visit, page views, and navigation paths.

We collect this data when you: submit forms or correspond with us via

email; browse our website (via cookies and similar technologies, as

described in Part B); or engage with us in any business capacity.

4. Lawful Bases for Processing

We rely on the following lawful bases under UK GDPR Article 6(1):

consent for us to process your personal data for a specific purpose.

You may withdraw consent at any time by contacting us.

for our legitimate interests or those of a third party, provided

your interests and fundamental rights do not override those

interests. Our legitimate interests include: operating and improving

this website, responding to enquiries, and protecting the Company's

legal rights.

compliance with a legal obligation to which we are subject,

including obligations under the Companies Act 2006, anti-money

laundering legislation, and tax law.

5. Data Retention

Personal data is retained only for as long as necessary for the purposes

for which it was collected, or as required by applicable law. Our

specific retention periods are:

correspondence, unless a longer retention period is required by law

or legitimate business need.

as required by HMRC and the Companies Act 2006. end of business relationship, whichever is later (MLR 2017).

6. Data Sharing

We may share personal data with the following categories of recipients:

administration. or joint controllers. data processing agreements.

We do not sell personal data to third parties. We do not share personal

data with third parties for their direct marketing purposes.

7. Data Transfers

Where personal data is transferred outside the United Kingdom to a

country that has not been deemed to provide an adequate level of data

protection, we ensure that appropriate safeguards are in place in

accordance with UK GDPR Article 46. These safeguards include the

International Data Transfer Agreement (UK IDTA) or the EU standard

contractual clauses with the UK Addendum, as approved by the Information

Commissioner's Office.

8. Your Rights

Under UK GDPR, you have the following rights:

process your personal data and to receive a copy of that data. corrected. certain circumstances ('right to be forgotten'). processing of your personal data in certain circumstances. in a structured, commonly used, and machine-readable format. legitimate interests, including profiling. engage in automated decision-making, including profiling, that

produces legal or similarly significant effects.

To exercise any of these rights, please contact:

dpo@theNeobankers.group. We will respond to your request within one

month. In exceptional circumstances, we may extend this period by a

further two months, and we will inform you if this is necessary.

You also have the right to lodge a complaint with the Information

Commissioner's Office (ICO). The ICO can be contacted at: ico.org.uk,

or by telephone on 0303 123 1113, or by post at: Information

Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire,

SK9 5AF.

9. Data Security

We implement appropriate technical and organisational measures to

protect personal data against unauthorised access, accidental loss,

destruction, or damage. These measures include encryption of data in

transit, access controls, and regular review of our security practices.

10. Changes to This Policy

This Privacy Policy may be updated from time to time. The date of the

most recent revision and the version number are indicated at the top of

this document. We encourage you to review this policy periodically.

PART B –- COOKIE POLICY

11. What Are Cookies

Cookies are small text files placed on your device when you visit a

website. They are widely used to make websites work or work more

efficiently, and to provide reporting information to the website

operator.

12. Legal Basis

We use cookies in accordance with regulation 6 of the Privacy and

Electronic Communications (EC Directive) Regulations 2003 (SI 2003/2426)

(PECR) and the UK GDPR. We obtain your consent before placing any

non-essential cookies on your device. Strictly necessary cookies do not

require your consent.

13. Categories of Cookies We Use

Strictly necessary cookies: These are essential for the operation of our

website. They enable core functionality such as security, network

management, and account access. These cookies do not require your

consent and cannot be disabled.

Analytics cookies: These allow us to recognise and count the number of

visitors and to see how visitors move around our website when they are

using it. This helps us to improve the way our website works, for

example by ensuring that users can find what they are looking for

easily. These cookies require your consent before they are placed.

We do not use advertising, targeting, or social media cookies.

14. Specific Cookies

A detailed list of the cookies we use, their purpose, and their expiry

period is available upon request by contacting: dpo@theNeobankers.group.

15. Managing Cookies

You may manage your cookie preferences at any time through our

Cookie Preference Centre or through your browser settings.

Most browsers allow you to refuse or delete cookies. The methods for

doing so vary from browser to browser. You may also withdraw your

consent at any time by clearing cookies from your browser.

Please note that if you disable or refuse cookies, some parts of this

website may become inaccessible or not function properly.

16. Further Information

For further information about cookies, including how to see what cookies

have been set and how to manage and delete them, visit:

allaboutcookies.org.

PART C –- PERSONAL DATA PROCESSING

17. Transparency Notice (UK GDPR Articles 13 and 14)

This section provides additional transparency regarding the processing

of personal data by the Company, in fulfilment of the requirements of UK

GDPR Articles 13 and 14.

18. Categories of Data Subjects

We process personal data relating to: website visitors; enquirers and

correspondents; business contacts and partners; directors and officers

of the Company and its current and future subsidiaries; and suppliers

and service providers.

19. Purposes and Legal Bases

The purposes for which we process personal data, and the corresponding

legal bases, are set out in sections 4 and 5 of Part A above. In

summary: website operation and analytics (legitimate interest);

responding to enquiries (consent or legitimate interest); corporate

administration and governance (legal obligation and legitimate

interest); and compliance with legal and regulatory obligations (legal

obligation).

20. Recipients

The categories of recipients with whom we may share personal data are

set out in section 6 of Part A above.

21. Automated Decision-Making

We do not engage in automated decision-making, including profiling, that

produces legal or similarly significant effects concerning individuals.

–- END OF DOCUMENT –-

← Back The Neobankers Group
The Neobankers Group Limited
Company No. 13821747 · 167-169 Great Portland Street, 5th Floor, London, W1W 5PF
March 2026 · Version 1.0 · Adopted by the Board · Next review: March 2027

167-169 Great Portland Street, 5th Floor, London, W1W 5PF, United

Kingdom

Version 1.0 \| Adopted by the Board \| Effective \| Next

review: March 2027

Code of Ethics

*Standards of conduct, anti-bribery, conflicts of interest, and

whistleblowing*

PART A –- CODE OF CONDUCT

1. Purpose and Scope

This Code of Ethics sets out the standards of behaviour expected of all

directors, officers, employees, consultants, and associates of The

Neobankers Group Limited and its current and future subsidiaries

(collectively, the 'Group'). It applies in all jurisdictions in which

the Group operates or intends to operate.

2. Core Principles

Integrity: We act honestly and ethically in all business dealings. We do

not misrepresent the Group's status, capabilities, or regulatory

position. We conduct ourselves in a manner that upholds the reputation

of the Group.

Compliance: We comply with all applicable laws, regulations, and

internal policies in every jurisdiction in which the Group operates or

intends to operate. Where there is a conflict between local law and this

Code, the stricter standard applies, provided it does not require a

breach of local law.

Respect: We treat all individuals with dignity, fairness, and respect,

regardless of background, position, or affiliation. The Group does not

tolerate harassment, bullying, victimisation, or discrimination in any

form.

Accountability: Each individual is personally responsible for their

conduct and for reporting concerns about potential violations of this

Code. Ignorance of the Code is not a defence.

Confidentiality: All non-public information relating to the Group, its

business plans, financial position, clients, and partners must be

treated as strictly confidential and may not be disclosed without proper

authorisation.

3. Compliance with Laws

All persons subject to this Code must comply with applicable laws and

regulations, including but not limited to: the Companies Act 2006, the

UK Bribery Act 2010, the Proceeds of Crime Act 2002, the Terrorism Act

2000, the Money Laundering Regulations 2017, the Sanctions and

Anti-Money Laundering Act 2018, the Equality Act 2010, the UK GDPR, the

Data Protection Act 2018, and all applicable sanctions regimes.

PART B –- ANTI-BRIBERY AND CORRUPTION

4. Zero Tolerance

The Neobankers Group Limited has a zero-tolerance approach to bribery

and corruption. This Part is issued in compliance with the UK Bribery

Act 2010 (the 'Act').

5. Prohibited Conduct

The following conduct is strictly prohibited:

accepting a bribe, whether in the form of money, gifts, hospitality,

or any other advantage.

practice. prohibition.

6. Offences Under the Act

The UK Bribery Act 2010 creates four offences: bribing another person

(s.1), being bribed (s.2), bribing a foreign public official (s.6), and

failure by a commercial organisation to prevent bribery (s.7). All four

offences apply to the Group. Penalties include unlimited fines and

imprisonment of up to 10 years.

7. Gifts and Hospitality

Gifts and hospitality may be offered or accepted only where they are

reasonable, proportionate, transparent, and recorded. Any gift or

hospitality with a value exceeding GBP 100 must be approved in advance

by a director. Lavish or disproportionate gifts and hospitality are

prohibited regardless of value.

8. Due Diligence on Third Parties

The Group conducts risk-based due diligence on all business partners,

agents, consultants, and intermediaries before engagement. Due diligence

is proportionate to the assessed bribery risk and is refreshed at

appropriate intervals.

9. Record-Keeping

All payments, gifts, and hospitality must be accurately and promptly

recorded in the Group's books and records. The Group maintains

financial records sufficient to demonstrate that transactions are

legitimate and that adequate procedures are in place to prevent bribery.

PART C –- CONFLICTS OF INTEREST

10. Identification and Disclosure

A conflict of interest arises where a director, officer, or associate

has a personal interest, direct or indirect, that conflicts or may

conflict with the interests of the Company. This includes situations

where a person has a duty to another party that conflicts with their

duty to the Company. All actual or potential conflicts of interest must

be disclosed promptly to the Board.

11. Duty to Declare (Companies Act 2006)

Directors have a statutory duty to declare interests under the Companies

Act 2006:

arrangement. arrangement.

Declarations must be made to the Board at the earliest opportunity. A

general notice under section 185 is acceptable where the nature and

extent of the interest are disclosed.

12. Related-Party Relationships

All related-party relationships are disclosed in accordance with FRS

102, Section 33 (Related Party Disclosures). Current related-party

relationships are documented and reviewed by the Board at least

annually. Transactions with related parties are conducted on arm's

length terms.

13. Management of Conflicts

Where a conflict is identified, the Board may: authorise the conflict

subject to conditions (including exclusion from votes and discussions);

require the conflicted person to recuse themselves from relevant

decisions; or determine that the conflict cannot be managed and require

the relationship to be terminated.

14. Register of Interests

The Company maintains a register of directors' interests. Directors are

required to update the register promptly upon any change in their

circumstances. The register is reviewed by the Board at each scheduled

meeting.

PART D –- WHISTLEBLOWING

15. Purpose

The Neobankers Group Limited is committed to conducting business with

integrity. This Part provides a framework for individuals to raise

concerns about suspected wrongdoing without fear of retaliation, in

accordance with the Public Interest Disclosure Act 1998 (PIDA) and the

Employment Rights Act 1996, Part IVA.

16. Scope

This Part applies to all directors, officers, employees, consultants,

and associates of the Group, as well as any person who has a business

relationship with the Group, including suppliers, contractors, and

partners.

17. What Can Be Reported

Concerns that may be reported under this Part include:

18. How to Report

Concerns may be reported in writing to: compliance@theNeobankers.group,

marked 'Confidential –- Whistleblowing'. Reports may also be made

verbally to any director of the Company. Anonymous reports will be

accepted and investigated to the extent possible, although the ability

to investigate may be limited.

19. Confidentiality

All reports will be treated in confidence to the extent possible. The

identity of the reporter will not be disclosed without their consent,

except where required by law or where disclosure is necessary for the

purposes of the investigation.

20. Protection Against Retaliation

No individual will be subjected to any detriment, disciplinary action,

dismissal, or other adverse treatment as a result of making a disclosure

in good faith under this Part. Any retaliation against a whistleblower

will be treated as a serious disciplinary matter and may itself

constitute a criminal offence under PIDA.

21. Investigation

All reports will be assessed promptly by the Board or a designated

officer. Where appropriate, an independent investigation will be

commissioned. The reporter will be informed of the outcome to the extent

permissible by law and having regard to the rights of other persons.

22. External Reporting

If you are not satisfied with the response to your report, or if you

reasonably believe that the matter has not been adequately addressed,

you may report the matter to the appropriate prescribed person or body,

including: the Serious Fraud Office, the National Crime Agency, HMRC,

the Information Commissioner's Office, or any other relevant regulator.

PART E –- CONSEQUENCES

23. Enforcement

Violations of this Code of Ethics may result in disciplinary action, up

to and including termination of engagement, referral to appropriate law

enforcement or regulatory authorities, and civil proceedings for

recovery of loss.

–- END OF DOCUMENT –-

← Back The Neobankers Group
The Neobankers Group Limited
Company No. 13821747 · 167-169 Great Portland Street, 5th Floor, London, W1W 5PF
March 2026 · Version 1.0 · Adopted by the Board · Next review: March 2027

167-169 Great Portland Street, 5th Floor, London, W1W 5PF, United

Kingdom

Version 1.0 \| Adopted by the Board \| Effective \| Next

review: March 2027

Anti-Money Laundering & Sanctions Policy

*Proceeds of Crime Act 2002, Money Laundering Regulations 2017, and

applicable sanctions regimes*

PART A –- ANTI-MONEY LAUNDERING

1. Policy Statement

The Neobankers Group Limited is committed to the prevention of money

laundering and terrorist financing. Although the Company does not

currently conduct regulated financial services activity itself, it

maintains this policy as a matter of corporate governance and

institutional best practice. Obligations under the Proceeds of Crime Act

2002, sections 327 to 332, apply to all persons in the United Kingdom,

not only to firms within the regulated sector.

2. Legal Framework

This policy is informed by:

laundering offences) and Part 9 (civil recovery). (Information on the Payer) Regulations 2017 (MLR 2017), as amended. and Terrorist Financing (most recent edition).

3. Money Laundering Offences

Under POCA, the principal money laundering offences are:

removing criminal property. which facilitates the acquisition, retention, use, or control of

criminal property.

The failure-to-disclose offences (ss. 330-332) apply to all persons

within the regulated sector. For persons outside the regulated sector,

the primary offences (ss. 327-329) still apply, and the authorised

disclosure defence (s. 338) is available.

4. Know Your Customer

The Group conducts appropriate customer due diligence (CDD) on all

business relationships and significant one-off transactions. CDD

measures include:

independent sources. counterparties. relationship. of transactions.

Enhanced due diligence (EDD) is applied where a higher risk of money

laundering or terrorist financing is identified, including but not

limited to: politically exposed persons (PEPs), high-risk jurisdictions

identified by FATF, complex or unusual transaction structures, and

counterparties with opaque ownership structures.

5. Suspicious Activity Reporting

Any director, officer, or associate who knows or suspects, or has

reasonable grounds for knowing or suspecting, that a person is engaged

in money laundering or terrorist financing must report their concern to

the Company's designated officer at: compliance@theNeobankers.group.

The designated officer will assess the report and determine whether a

Suspicious Activity Report (SAR) should be filed with the National Crime

Agency (NCA) in accordance with POCA ss. 330-332 or s. 338 (authorised

disclosure). No director, officer, or associate shall make any

disclosure to a third party that might prejudice an investigation

('tipping off' –- POCA s. 333A).

6. Record-Keeping

Records of all customer due diligence measures and transactions are

retained for a minimum of five years from the date of the transaction or

the end of the business relationship, whichever is later, in accordance

with MLR 2017 Regulation 40.

7. Training

All directors and relevant staff receive training on their obligations

under anti-money laundering legislation. Training is provided at

induction and refreshed at regular intervals (at least annually).

Training covers: the legal framework, identification of suspicious

activity, internal reporting procedures, and the consequences of

non-compliance.

PART B –- SANCTIONS

8. Policy Statement

The Neobankers Group Limited complies with all applicable financial

sanctions regimes, including:

Sanctions Implementation (OFSI), a division of HM Treasury, under

SAMLA 2018 and relevant statutory instruments.

Union under the Common Foreign and Security Policy (CFSP). sanctions administered by the Office of Foreign Assets Control

(OFAC), a division of the US Department of the Treasury.

9. Prohibited Activities

The Group will not enter into any transaction, business relationship, or

arrangement with any person, entity, or country that is the subject of

applicable financial sanctions. The Group will not, directly or

indirectly, facilitate any transaction that would result in a breach of

applicable sanctions, including the provision of financial services, the

making available of funds or economic resources, or any other act

prohibited by the relevant sanctions regime.

10. Screening

All counterparties, business partners, directors, beneficial owners, and

transactions are screened against current UK (OFSI) and EU sanctions

lists prior to engagement and on an ongoing basis. Where applicable to

the Group's activities, US (OFAC) lists are also screened. Screening is

repeated at appropriate intervals and whenever there is a change in the

sanctions lists or in the counterparty's circumstances.

11. Reporting

If any director, officer, or associate becomes aware of a potential

sanctions breach, they must report it immediately to the designated

officer at: compliance@theNeobankers.group. The Company will report

confirmed breaches to OFSI as required by SAMLA 2018 and to other

relevant authorities as required by law. OFSI publishes guidance on

monetary penalties for sanctions breaches; the maximum penalty for a

serious breach is unlimited.

12. Penalties

Breach of UK financial sanctions is a criminal offence. Penalties under

SAMLA 2018 and the relevant statutory instruments include imprisonment

of up to 7 years and unlimited fines. OFSI may also impose monetary

penalties on a strict liability basis. The Company takes sanctions

compliance with the utmost seriousness.

13. Review

This policy is reviewed at least annually and upon any material change

in applicable sanctions regimes. Amendments are approved by the Board.

–- END OF DOCUMENT –-

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The Neobankers Group Limited
Company No. 13821747 · 167-169 Great Portland Street, 5th Floor, London, W1W 5PF
March 2026 · Version 1.0 · Adopted by the Board · Next review: March 2027

167-169 Great Portland Street, 5th Floor, London, W1W 5PF, United

Kingdom

Version 1.0 \| Adopted by the Board \| Effective \| Next

review: March 2027

Risk Disclosure

General risk factors applicable to the Group's business direction

1. Purpose

This document identifies the principal risk factors associated with the

Group's business direction and strategic objectives. It is provided for

informational purposes only and does not constitute investment advice, a

recommendation, or an offer to sell or a solicitation to buy any

security.

2. General Business Risk

The Group is at an early stage of development. There can be no assurance

that the Group's strategic objectives will be achieved, that its

current and future subsidiaries will obtain the regulatory

authorisations they seek, or that its products and services will achieve

market acceptance. Early-stage companies have a high rate of failure,

and an investment in or engagement with the Group should be considered

in light of the risks, costs, and difficulties frequently encountered by

early-stage enterprises.

3. Regulatory Risk

The Group's business direction involves areas that are subject to

extensive, complex, and rapidly evolving regulation across multiple

jurisdictions. These include, but are not limited to, electronic money

regulations, payment services regulations, anti-money laundering

requirements, data protection law, and digital asset regulation. Changes

in law, regulation, regulatory interpretation, or enforcement practice

may adversely affect the Group's ability to operate or the commercial

viability of its business. There can be no assurance that the Group will

obtain or maintain the regulatory authorisations it requires.

4. Technology Risk

The Group's business depends on the successful development, deployment,

and operation of complex technology platforms. Technology systems are

inherently subject to risks including software defects, hardware

failure, cyberattack, data breach, service outages, and technological

obsolescence. There can be no assurance that the Group's technology

will perform as intended or that it will be secure against all threats.

5. Market and Competition Risk

The markets in which the Group intends to operate are competitive and

subject to rapid change. The Group will compete with established

financial institutions, other fintech companies, and new market

entrants. Many competitors have significantly greater financial,

technical, and marketing resources. There can be no assurance that the

Group will be able to compete effectively or that its competitive

position will be maintained.

6. Financial Risk

The Group requires capital to fund its development. There can be no

assurance that additional capital will be available on acceptable terms

or at all. Failure to obtain sufficient capital may require the Group to

delay, scale back, or abandon some or all of its business plans. The

Group has a limited operating history and has not yet generated

significant revenue.

7. Key Personnel Risk

The Group's success depends on the continued services and contributions

of its directors, officers, and key personnel. The loss of any key

individual could materially and adversely affect the Group's business,

financial condition, and prospects.

8. Counterparty and Credit Risk

The Group may be exposed to the risk that counterparties –- including

business partners, service providers, and financial institutions –- may

fail to meet their obligations. Such failure could result in financial

loss and disruption to the Group's operations.

9. Geopolitical and Macroeconomic Risk

The Group's business may be adversely affected by changes in

geopolitical conditions, macroeconomic trends, interest rates,

inflation, currency fluctuations, and other factors beyond its control.

10. Forward-Looking Statements

This website and associated documents may contain forward-looking

statements. These statements are based on the Group's current

expectations and assumptions and involve known and unknown risks,

uncertainties, and other factors which may cause actual results,

performance, or achievements to differ materially from those expressed

or implied. The Company undertakes no obligation to update

forward-looking statements.

–- END OF DOCUMENT –-

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The Neobankers Group Limited
Company No. 13821747 · 167-169 Great Portland Street, 5th Floor, London, W1W 5PF
March 2026 · Version 1.0 · Adopted by the Board · Next review: March 2027

167-169 Great Portland Street, 5th Floor, London, W1W 5PF, United

Kingdom

Version 1.0 \| Adopted by the Board \| Effective \| Next

review: March 2027

Modern Slavery Statement

*Voluntary statement applying the principles of the Modern Slavery Act

2015, Section 54*

1. Statement

This statement is made voluntarily by The Neobankers Group Limited,

applying the principles of Section 54 of the Modern Slavery Act 2015

(the 'Act'). The mandatory reporting obligation under Section 54

applies to commercial organisations with an annual turnover of GBP 36

million or more. The Company does not currently meet this threshold;

however, it publishes this statement as a matter of good corporate

governance and institutional best practice.

This statement sets out the steps taken by the Company during the

financial year ending 31 to prevent modern slavery and human

trafficking in its business and supply chains.

2. Organisation Structure

The Neobankers Group Limited is a private limited company incorporated

in England and Wales on 30 December 2021 (). The

Company is a holding company focused on fintech, blockchain, and digital

assets. The Company's operations are primarily digital and

knowledge-based, with no physical production facilities or manual labour

supply chains.

3. Our Supply Chains

Our supply chains consist principally of:

consulting, and tax advisory. (IaaS/PaaS), IT consulting, and cybersecurity services. and business insurance.

We assess these supply chains as low-risk for modern slavery and human

trafficking, given their nature (knowledge-based professional and

technology services) and the jurisdictions in which our principal

suppliers operate (United Kingdom, European Economic Area, and

Switzerland). We are not aware of any modern slavery or human

trafficking in our supply chains.

4. Policies

The Group maintains the following policies relevant to modern slavery

prevention:

act with integrity and to comply with all applicable laws. The Code

specifically prohibits any conduct that would constitute or

facilitate modern slavery or human trafficking.

any person to raise concerns about suspected wrongdoing, including

concerns about modern slavery, without fear of retaliation.

5. Due Diligence

We conduct proportionate due diligence on new suppliers and business

partners. For suppliers assessed as higher risk (e.g., those operating

in jurisdictions with a higher prevalence of modern slavery), we require

confirmation of compliance with applicable modern slavery legislation

and may request additional information regarding their supply chain

management practices.

6. Training and Awareness

Directors and relevant personnel are made aware of the risks of modern

slavery and human trafficking and their obligations under the Act.

Awareness is raised as part of broader ethics and compliance training.

7. Key Performance Indicators

During the reporting period, we record the following: number of modern

slavery concerns reported (zero); number of suppliers assessed for

modern slavery risk (all new suppliers); and number of supply chain

audits conducted for modern slavery (not applicable given the nature of

our supply chains).

8. Approval

This statement has been approved by the Board of Directors of the

Company and signed on its behalf.

–- END OF DOCUMENT –-

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The Neobankers Group Limited
Company No. 13821747 · 167-169 Great Portland Street, 5th Floor, London, W1W 5PF
March 2026 · Version 1.0 · Adopted by the Board · Next review: March 2027

Accessibility Statement

Equality Act 2010 and Web Content Accessibility Guidelines (WCAG) 2.1 Level AA

1. Commitment

The Neobankers Group Limited is committed to ensuring that this website (theNeobankers.group) is accessible to all users, including persons with disabilities, in accordance with the Equality Act 2010 and the Web Content Accessibility Guidelines (WCAG) 2.1 at Level AA, published by the World Wide Web Consortium (W3C).

2. Measures Taken

We have taken the following measures to ensure accessibility:

3. Known Limitations

We are aware of the following accessibility limitations:

We will provide accessible alternatives to any inaccessible content upon request.

4. Compatibility

This website is designed to be compatible with the following assistive technologies: screen readers (including JAWS, NVDA, and VoiceOver); screen magnification software; and speech recognition software. The website is designed to be compatible with current versions of major browsers (Chrome, Firefox, Safari, Edge).

5. Feedback and Contact

If you experience any difficulty accessing any part of this website, or if you have suggestions for improving accessibility, please contact us at: post.box@theNeobankers.group. We will make reasonable efforts to respond within five business days.

6. Enforcement

If you are not satisfied with our response, you may contact the Equality Advisory and Support Service (EASS) at: equalityadvisoryservice.com.

7. Review

This Accessibility Statement is reviewed annually and updated as necessary.

— END OF DOCUMENT —
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Connect

Newsroom & Contact

The Group’s press centre and principal channel for media, investor, and general enquiries. For press materials, regulatory announcements, and corporate communications, please refer to the relevant section below.

Media Contact
General Media Enquiries
For press enquiries, interview requests, and editorial commentary. The Group endeavours to respond on the same business day or by the following business day.
Investor Relations
For investor-related media enquiries, financial results commentary, and institutional communications. Directed to the Office of the Executive Chairman.
Corporate Contacts
Data Protection Officer
For GDPR subject access requests, data processing enquiries, and privacy-related matters. Designated pursuant to UK GDPR Article 37.
Compliance & Whistleblowing
For AML/sanctions enquiries, regulatory matters, and confidential whistleblowing disclosures under the Public Interest Disclosure Act 1998.
Our Location
Registered Office
The NeoBankers Group Limited
167–169 Great Portland Street
5th Floor
London W1W 5PF
United Kingdom
Company Number
13821747 (England & Wales)
Office Hours
Monday to Friday
11:00 AM – 5:00 PM (GMT/BST)
How to Reach Us
← Back The Neobankers Group

General Enquiry

Should you have any questions, require further information, or wish to discuss a potential matter, we invite you to contact us using the form below.

Do you have
a question or enquiry?
SEND US
AN EMAIL
Office Hours
Monday to Friday
11:00 AM – 5:00 PM (GMT/BST)
Local Date and Time
London, United Kingdom
--:--:--
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We endeavour to respond
on the same business day
or by the following business day.

Contact Information

We should be grateful if you would complete the form below so that we may direct your enquiry to the appropriate person.

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The NeoBankers Group Limited
Company No. 13821747 · 167-169 Great Portland Street, 5th Floor, London, W1W 5PF
April 2026 · Version 1.0 · Adopted by the Board · Next review: April 2027

Complaints Policy

Fair and transparent handling of complaints in accordance with the principles of good corporate governance and applicable law

1. Policy Statement

The NeoBankers Group Limited (the "Company") is committed to handling all complaints fairly, promptly, and transparently. The Company treats every complaint as an opportunity to improve its operations and to uphold the trust placed in it by investors, counterparties, and stakeholders.

2. Scope

This policy applies to complaints received from any person in connection with the Company or any member of the Group, including prospective and existing investors, contractual counterparties, service users, professional advisers, regulators, and members of the public. The policy extends to complaints received orally, in writing, or through electronic channels.

3. Definition of a Complaint

A complaint is any expression of dissatisfaction, whether oral or written, and whether or not justified, relating to the provision of, or failure to provide, a service, product, communication, or information by the Company or any member of the Group, where the complainant alleges that they have suffered, or may suffer, financial loss, material inconvenience, or material distress.

4. How to Submit a Complaint

Complaints may be submitted in writing to:

Email: compliance@theneobankers.group
Post: Complaints Officer, The NeoBankers Group Limited, 167–169 Great Portland Street, 5th Floor, London W1W 5PF, United Kingdom.

All complaints should include: (a) the complainant's full name and contact details; (b) a clear and detailed description of the matter giving rise to the complaint; (c) the date or dates on which the relevant events occurred; (d) copies of any relevant correspondence, contracts, or other documentation; and (e) the outcome sought by the complainant.

5. Acknowledgement

The Company will acknowledge receipt of a complaint in writing within five business days of receipt. The acknowledgement will identify the person responsible for handling the complaint and provide the complainant with a copy of this policy.

6. Investigation and Response

Each complaint will be investigated thoroughly, impartially, and with due regard to the rights and interests of all parties. The investigation will be conducted by a person of appropriate seniority who was not directly involved in the matter giving rise to the complaint. A substantive written response setting out the Company's findings and proposed resolution will be provided within eight weeks of receipt. Where the complaint cannot be resolved within eight weeks, the Company will write to the complainant explaining the reasons for the delay, the progress made, and the anticipated timeline for resolution.

7. Escalation

If the complainant is not satisfied with the Company's response, the matter may be referred in writing to the Board of Directors for further review. The Board will consider the matter at its next scheduled meeting or, in the case of an urgent complaint, within 15 business days of receipt. The Board's determination will be communicated to the complainant in writing.

8. External Remedies

Nothing in this policy limits the complainant's right to seek independent legal advice, to refer the matter to any applicable ombudsman, regulator, or dispute resolution body, or to pursue any available legal remedy. As the Company is not authorised or regulated by the Financial Conduct Authority, the Financial Ombudsman Service does not have jurisdiction over the Company's activities at the date of this policy.

9. Record-Keeping

The Company maintains a confidential register of all complaints received, including the date of receipt, identity of the complainant, nature of the complaint, actions taken during the investigation, and the final outcome. This register is reviewed by the Board on a periodic basis and is retained for a minimum of six years from the date of resolution.

10. Confidentiality

All complaints will be treated in confidence. Information relating to a complaint will be disclosed only to those persons within the Company who are directly involved in its investigation and resolution, and to external parties where required by law or regulation.

11. Review

This policy is reviewed and, where necessary, updated on an annual basis by the Board. The next scheduled review is April 2027.

12. Governing Law

This policy is governed by the laws of England and Wales.

— End of Document —
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The NeoBankers Group Limited
Company No. 13821747 · 167-169 Great Portland Street, 5th Floor, London, W1W 5PF
April 2026 · Version 1.0 · Adopted by the Board · Next review: April 2027

Conflicts of Interest Policy

Identification, disclosure, and management of conflicts of interest in accordance with the Companies Act 2006 and principles of institutional governance

1. Policy Statement

The NeoBankers Group Limited (the "Company") recognises that conflicts of interest may arise in the ordinary course of its business as a holding company with equity interests in multiple operating subsidiaries, and through its relationships with directors, officers, shareholders, external advisers, service providers, and counterparties. The Company is committed to identifying, disclosing, and managing all actual and potential conflicts fairly and transparently, and to avoiding conflicts where they cannot be adequately managed.

2. Legal Framework

This policy is informed by:

3. Identification of Conflicts

A conflict of interest arises where the interests of the Company, any member of the Group, any director, officer, employee, shareholder, or connected person diverge from, or may reasonably be perceived to diverge from, the interests of investors, clients, counterparties, or other stakeholders. This includes, without limitation:

4. Disclosure

All actual or potential conflicts of interest must be disclosed promptly to the Board of Directors. Directors are required to declare any interest in a proposed transaction or arrangement in accordance with section 177 of the Companies Act 2006, and any interest in an existing transaction or arrangement in accordance with section 182. Declarations must be made at the earliest practicable opportunity, and in any event before the Company enters into the relevant transaction. The Company maintains a register of directors' interests, which is updated on an ongoing basis.

5. Management and Mitigation

Where a conflict is identified, the Board shall determine the appropriate course of action, which may include one or more of the following measures:

6. Related-Party Transactions

The Company maintains a register of related-party relationships and transactions, as required by IAS 24 and applicable accounting standards. All related-party transactions are conducted on arm's-length terms or, where arm's-length terms cannot be demonstrated, are subject to independent valuation, review, and Board approval. The related-party register is available for inspection by the Company's auditors and, where applicable, by qualified investors under the terms of a Non-Disclosure Agreement.

7. Gifts and Hospitality

Directors, officers, and employees must not offer or accept any gift, payment, or hospitality that could reasonably be perceived as creating a conflict of interest, or that could impair, or appear to impair, their independent judgement. Any gift or hospitality exceeding a de minimis threshold established by the Board must be declared in writing and recorded in the Company's gifts and hospitality register.

8. Record-Keeping and Review

The Company maintains a conflicts register, which is updated on an ongoing basis. The register records all identified conflicts, the measures taken to manage them, and their resolution. The Board reviews the conflicts register and this policy no less than annually. The next scheduled review is April 2027.

9. Breach

Any failure to disclose a conflict of interest or to comply with this policy may result in disciplinary action and, where applicable, personal liability under the Companies Act 2006 or at common law.

10. Governing Law

This policy is governed by the laws of England and Wales.

— End of Document —
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The NeoBankers Group Limited
Company No. 13821747 · 167-169 Great Portland Street, 5th Floor, London, W1W 5PF
April 2026 · Version 1.0 · Adopted by the Board · Next review: April 2027

Whistleblowing Policy

Public Interest Disclosure pursuant to the Public Interest Disclosure Act 1998 and the Employment Rights Act 1996, Part IVA

1. Policy Statement

The NeoBankers Group Limited (the "Company") is committed to maintaining the highest standards of integrity, transparency, and accountability in all its activities. The Company encourages any person who has genuine concerns about suspected wrongdoing to report those concerns without fear of retaliation. This policy provides a safe, confidential, and accessible framework for the making of such reports.

2. Legal Framework

This policy is informed by:

3. Scope

This policy applies to all directors, officers, employees, consultants, contractors, agency workers, interns, and any other person who performs work for or on behalf of the Company or any member of the Group. It also applies to external parties, including investors, counterparties, service providers, and members of the public, who wish to report concerns in good faith.

4. Qualifying Disclosures

A qualifying disclosure is a disclosure of information which, in the reasonable belief of the person making it, is made in the public interest and tends to show that one or more of the following has occurred, is occurring, or is likely to occur:

5. How to Report

Concerns may be reported confidentially to:

Email: compliance@theneobankers.group
Post: Compliance Officer (Confidential), The NeoBankers Group Limited, 167–169 Great Portland Street, 5th Floor, London W1W 5PF, United Kingdom.

Reports should include as much detail as practicable, including: (a) the nature of the concern; (b) the identity of the persons involved, where known; (c) the date or dates on which the relevant events occurred or were observed; (d) the location of the relevant events; and (e) any supporting evidence or documentation available to the reporting person.

Reports may be made anonymously. However, the Company encourages individuals to identify themselves where possible, as anonymous reports are inherently more difficult to investigate and may limit the protections available to the reporting person.

6. Confidentiality

The Company will treat all disclosures in the strictest confidence to the fullest extent permitted by law. The identity of the reporting person will not be disclosed without their express consent, unless disclosure is required by law, by order of a court or tribunal, or is strictly necessary for the effective conduct of the investigation. All persons involved in the investigation are required to maintain confidentiality.

7. Protection from Retaliation

The Company will not tolerate any form of retaliation, detriment, victimisation, harassment, or disciplinary action against any person who makes a qualifying disclosure in good faith. Workers who make a protected disclosure are protected from unfair dismissal under section 103A of the Employment Rights Act 1996. Any person who subjects a whistleblower to detriment will be subject to disciplinary proceedings, which may include summary dismissal, and may incur personal liability at law.

8. Investigation

All reports received under this policy will be assessed promptly by the Compliance Officer. Where the report raises a matter that warrants investigation, the Company will conduct a thorough and impartial investigation, which may include interviews with relevant persons, review of documentation, and, where appropriate, engagement of external advisers or forensic specialists. The Company will provide feedback to the reporting person on the outcome of the investigation within a reasonable timeframe, subject to the requirements of confidentiality, legal privilege, and any ongoing investigation or legal proceedings.

9. External Reporting

Nothing in this policy prevents any person from making a disclosure to a prescribed person or body under the Public Interest Disclosure (Prescribed Persons) Order 2014 (SI 2014/2418). In the context of financial services and financial crime, relevant prescribed persons include:

The Company respects the right of any person to make a disclosure to a prescribed person and will not treat such disclosure as a breach of confidence or of any contractual obligation, including any Non-Disclosure Agreement.

10. Record-Keeping

The Company maintains a confidential register of all reports received under this policy, including the date of receipt, nature of the concern, actions taken during the investigation, and the final outcome. This register is reviewed by the Board on a periodic basis and is retained in accordance with the Company's data retention policy and applicable law.

11. Review

This policy is reviewed and, where necessary, updated on an annual basis by the Board. The next scheduled review is April 2027.

12. Governing Law

This policy is governed by the laws of England and Wales.

— End of Document —
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The NeoBankers Group Limited
Company No. 13821747 · 167-169 Great Portland Street, 5th Floor, London, W1W 5PF
April 2026 · Version 1.0 · Adopted by the Board · Next review: April 2027

Tax Strategy

Published voluntarily in the spirit of Schedule 19 to the Finance Act 2016 and in accordance with the Group's commitment to transparency in tax matters

1. Introduction

The NeoBankers Group Limited (the "Company") publishes this tax strategy voluntarily, notwithstanding that the Group does not currently meet the qualifying thresholds under paragraph 2 of Schedule 19 to the Finance Act 2016 (turnover exceeding £200 million or balance sheet total exceeding £2 billion). The Board considers transparency in tax matters to be an integral element of sound corporate governance and institutional credibility.

2. Board Responsibility

The Board of Directors has ultimate responsibility for the Group's tax strategy, tax risk management, and tax compliance. The Board is supported by the Group CFO and by qualified external tax advisers engaged on a jurisdiction-by-jurisdiction basis. Material tax decisions, including changes to the Group's tax structure, are reserved to the Board.

3. Approach to Tax Risk

The Group maintains a low tolerance for tax risk. Tax risk is managed through a combination of internal controls, independent external advice, and Board oversight. The Board is informed of all material tax risks and their management. The Group does not take aggressive tax positions and will not participate in arrangements that could bring the Group into disrepute or into conflict with its stated values of transparency and integrity.

4. Tax Planning Principles

The Group's approach to tax planning is guided by the following principles:

5. Multi-Jurisdictional Operations

The Group operates through subsidiaries in multiple jurisdictions. Each entity is subject to the tax laws of its jurisdiction of incorporation and, where applicable, the jurisdiction in which it conducts economic activity. The Group maintains appropriate substance — including personnel, premises, and decision-making capacity — in each jurisdiction, and does not allocate profits to entities that lack genuine economic substance. The Group's blended effective tax rate is based on the applicable corporate tax rates of the jurisdictions in which its subsidiaries operate.

6. Relationship with Tax Authorities

The Group seeks to maintain an open, transparent, and cooperative relationship with HM Revenue & Customs ("HMRC") and the tax authorities of all jurisdictions in which it operates. The Group makes accurate and timely tax filings in each jurisdiction. Where there is uncertainty as to the application of tax law, the Group will seek to resolve the matter through dialogue with the relevant tax authority, taking independent professional advice where appropriate. The Group responds promptly and fully to all enquiries from tax authorities.

7. Country-by-Country Reporting

Although the Group does not currently meet the thresholds for mandatory Country-by-Country Reporting under the OECD BEPS Action 13 framework, the Board will keep this position under review as the Group's operations scale. The Board is committed to adopting such reporting voluntarily if and when doing so would be proportionate to the Group's size and activities.

8. Review

This strategy is reviewed annually by the Board and updated as necessary to reflect changes in legislation, the Group's structure, or its commercial activities. The next scheduled review is April 2027.

9. Governing Law

This strategy is governed by the laws of England and Wales.

— End of Document —
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The NeoBankers Group Limited
Company No. 13821747 · 167-169 Great Portland Street, 5th Floor, London, W1W 5PF
April 2026 · Version 1.0 · Adopted by the Board · Next review: April 2027

ESG & Environmental Policy

Environmental, social, and governance commitment informed by the UN Sustainable Development Goals, the UK Modern Slavery Act 2015, and institutional governance standards

1. Purpose and Scope

The NeoBankers Group Limited (the "Company") recognises that responsible business conduct requires the integration of environmental, social, and governance ("ESG") factors into its strategy, operations, and decision-making. This policy sets out the Group's commitments and approach across each ESG dimension. It applies to the Company and all members of the Group.

2. Environmental Commitment

The Group operates a digital-first business model with no physical branch network, which inherently limits its direct environmental footprint. The Group is committed to:

3. Social Commitment

The Group's approach to social responsibility is informed by UN Sustainable Development Goals 1 (No Poverty), 8 (Decent Work and Economic Growth), 9 (Industry, Innovation and Infrastructure), 10 (Reduced Inequalities), and 16 (Peace, Justice and Strong Institutions). The Group is committed to:

4. Governance Commitment

The Group maintains governance standards aligned with institutional expectations, including:

5. Reporting and Transparency

The Group publishes its Modern Slavery Statement voluntarily and maintains publicly accessible policies on anti-money laundering and sanctions compliance, data protection, whistleblowing, complaints handling, conflicts of interest, and tax strategy. As the Group's operations scale, the Board will consider the adoption of formal ESG reporting frameworks, including:

The Board is committed to adopting such frameworks where doing so is proportionate to the Group's size, activities, and stakeholder expectations.

6. Stakeholder Engagement

The Group recognises the importance of maintaining open dialogue with its stakeholders on ESG matters, including investors, regulators, employees, clients, and the communities in which it operates. Stakeholder feedback on the Group's ESG performance is welcomed and may be directed to: post.box@theneobankers.group.

7. Review

This policy is reviewed annually by the Board and updated as necessary to reflect developments in legislation, best practice, and the Group's commercial activities. The next scheduled review is April 2027.

8. Governing Law

This policy is governed by the laws of England and Wales.

— End of Document —
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The NeoBankers Group Limited
Company No. 13821747 · Frequently Asked Questions

Frequently Asked Questions

1. What is The NeoBankers Group?

The NeoBankers Group Limited is an independent, international financial and technology holding group incorporated in England and Wales (Company No. 13821747). The Company holds equity interests in its operating subsidiaries, intellectual property, and registered trade marks. The Company does not itself conduct regulated financial services activity.

2. What is the Integrated Digital Financial Ecosystem?

The IDFE is a unified platform architecture that brings together regulated payments, digital asset services, collateralised lending, real-world asset tokenisation, and embedded insurance within a single compliance framework. It belongs to a category for which no established term yet exists in the financial services industry.

3. Is The NeoBankers Group a bank?

No. The Company is not a bank, a credit institution, an investment fund, or an investment firm within the meaning of applicable law. It is not authorised or regulated by the Financial Conduct Authority or the Prudential Regulation Authority. Regulated financial services activities are carried on by the Group’s operating subsidiaries, not by the Company.

4. How can I access the investment materials?

Detailed investment terms, the financial model, entity architecture, team biographies, and partnership structures are disclosed exclusively following execution of a mutual Non-Disclosure Agreement. To request access, navigate to the Investors section and select “Execute NDA & Request Access”, or contact the Company at founders@theneobankers.group.

5. Who can invest?

Any future investment opportunity, if offered, will be directed exclusively at persons who qualify as professional investors within the meaning of MiFID II, or as certified high net worth individuals or certified sophisticated investors within the meaning of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 (Articles 48 and 50). The Group does not accept investment from retail investors, US Persons (as defined in Regulation S under the US Securities Act of 1933), or persons subject to sanctions imposed by the United Kingdom (OFSI), the European Union, or the United States (OFAC).

6. Where is the Group incorporated?

The NeoBankers Group Limited is incorporated in England and Wales. The registered office is at 167–169 Great Portland Street, 5th Floor, London W1W 5PF, United Kingdom. The Group’s operating subsidiaries are established across multiple regulated jurisdictions. Details of the corporate structure are available to qualified investors upon execution of a Non-Disclosure Agreement.

7. How does the Group handle data protection?

The Company processes personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. The Group’s Privacy & Cookie Policy is available via the footer of this website. For GDPR subject access requests and data protection enquiries, contact the Data Protection Officer at dpo@theneobankers.group.

8. How can I contact the Group?

General enquiries: post.box@theneobankers.group. Investor relations: founders@theneobankers.group. Data protection: dpo@theneobankers.group. Compliance and whistleblowing: compliance@theneobankers.group. Media: media.box@theneobankers.group. The Group endeavours to respond on the same business day or the following business day.

— End of Document —
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The NeoBankers Group Limited
Company No. 13821747 · Website Sitemap

Sitemap

1. Discover

Our Company — Overview · Mindset · Values · Principles · Philosophy

Our Philanthropy — Financial Inclusion · Financial Literacy · Sustainability · ESG Integration

Our Businesses — Payments · Digital Assets · BaaS · Token Economy · IT & Technology · Licensing & Regulatory Advisory · Management Consulting · Business Development · Mergers & Acquisitions

Our Portfolio — Corporate structure available under NDA

Leadership Team — Executive Chairman · CEO · CFO · COO

From the Chairman — Chairman’s statement

Insights — IDFE: A Category Without a Name · The Convergence of Payments and Blockchain · Automation as Prerequisite, Not Feature

Frequently Asked Questions — 8 questions covering corporate structure, IDFE, regulation, investment access, jurisdiction, data protection, and contact

2. Investors

Investor Overview — Regulatory notice · Narrative · 70+ Products grid · Important Legal Notice (15 points) · NDA Gate

NDA Gate — Execute NDA & Request Access · Existing Credentials · Talk to the Team

3. Connect

Media Contact — General Media · Investor Relations · Data Protection · Compliance & Whistleblowing

Our Location — Registered Office · Office Hours · Contact channels

4. Policies (13 documents)

Legal Notice & Terms · Privacy & Cookie Policy · Cookie Preferences · Code of Ethics · AML & Sanctions Policy · Risk Disclosure · Modern Slavery Statement · Accessibility Statement · Complaints Policy · Conflicts of Interest Policy · Whistleblowing Policy · Tax Strategy · ESG & Environmental Policy

5. External Links

Companies House — Public Filings

LinkedIn · Facebook

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For Qualified Investors & Strategic Partners

Investor Overview

A new category of financial infrastructure is taking shape. This is an introduction to what we are building — and why it may matter.

Financial & Technology Holding Group — Pioneering the Integrated Digital Financial Ecosystem

The NeoBankers Group Limited is not a bank, credit institution, investment fund, or investment firm. Not authorised or regulated by the FCA or PRA. This page does not constitute a financial promotion, investment advice, or an invitation to invest. Forward-looking statements are inherently uncertain. Capital is at risk. Full Legal Notice ↓

The financial services industry is converging. Payments, digital assets, lending, insurance, and institutional infrastructure are collapsing into a single architecture. The question is no longer whether this will happen — but who will build it, and under what regulatory framework.

Today, a consumer or business operating across borders must maintain separate relationships for banking, digital assets, credit, insurance, and investment. Each with its own KYC, its own fee structure, its own custody risk. The infrastructure was designed for a single-currency, single-jurisdiction, single-asset world. That world no longer exists.

We are building what comes next: a unified, regulated, multi-jurisdictional financial ecosystem that treats fiat currency and digital assets as equal-status instruments within one platform, one compliance framework, and one client relationship. Not a neobank. Not an exchange. Not a payments company. A new category — one for which no established term yet exists in the industry.

The architecture is proprietary. The technology kernel is built from first principles — not assembled from third-party modules. The regulatory perimeter spans multiple jurisdictions, with each activity independently licensed. The licensing programme alone represents years of work and significant capital that cannot be replicated quickly.

The product suite exceeds seventy distinct financial services across five integrated sectors, delivered through a single client interface. No comparable offering exists on the market today. The architecture has no direct comparable on the market today.

We have contracted an anchor client base through institutional partnership agreements. Revenue operations are supported by active regulatory registrations. The platform is built. The team is assembled. The governance framework meets institutional standards.

What remains is the final stage: execution at scale. We are seeking qualified investors and strategic partners who understand that the most consequential infrastructure projects are funded before they are obvious.

The full investment thesis, financial model, entity architecture, team biographies, and partnership structures are disclosed exclusively under a mutual Non-Disclosure Agreement.

70+ Products Across Five Sectors
IQ Banking
Multi-currency IBAN · SEPA/SWIFT · Faster Payments · PSD2 Open Banking
IQ Blockchain
MiCA CASP custody · Exchange & OTC · TVTG Token Container · 50+ ERC-20
IQ Lending
Collateralised digital lending · SME credit · Deferred payment · Factoring · Overdraft
Seamless Cards
Debit cards (major networks) · Virtual + physical · Multi-asset spend · Mobile wallet
Multi-Asset Accounts
Fiat + blockchain + metals + securities · One portfolio · One KYC
Escrow & Settlement
Programmable escrow · Smart contract triggers · Marketplace settlements
RWA Tokenisation
TVTG Token Container · Real estate, commodities on-chain · Fractional investment
Tax-Free Shopping
Instant VAT refund via EMT · In-app disbursement · Tourist integration
Insurance & Investment
Parametric smart contracts · Protocol cover · Embedded insurance
Own EMT Token
Fiat-backed €1.00 MiCA-regulated · Cashback · Interchange · Governance
Tax & Accounting
Automated VAT reconciliation · Tax bookkeeping · Multi-jurisdiction
Staking & Yield
Staking vault · Institutional prime brokerage · Custody with institutional safeguards
Authorised Access

Execution of a mutual Non-Disclosure Agreement is required to access the Institutional Virtual Data Room.

Upon execution, you will receive view-only access to the Institutional Virtual Data Room: financial model, entity architecture, team biographies, regulatory portfolio, and investment terms.

Execute NDA & Request Access Existing Credentials Talk to the Team
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Investor Access

Authorised Personnel Only

Access to the Investor Portal is restricted to authorised individuals. Please enter your credentials below.

To request investor access credentials, please contact
nda_sa@theNeobankers.group

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Investor Access

Accept the NDA to access the Series A presentation

Personal Identification
Organisation
Investment Context
MiFID II Professional Investor Self-Certification
Data Protection — UK GDPR Article 13
Data controller: The Neobankers Group Limited, 167-169 Great Portland Street, 5th Floor, London, W1W 5PF (UK Co. 13821747).

Purposes: (a) verifying identity and authority; (b) administering VDR access; (c) sanctions and AML screening per MLR 2017; (d) maintaining NDA records; (e) communications regarding the Transaction.

Legal basis: Art. 6(1)(b) UK GDPR (pre-contractual steps) and Art. 6(1)(f) (legitimate interests). Optional data: Art. 6(1)(a) (consent, withdrawable).

Recipients: legal advisers, sanctions screening providers, regulatory authorities where required. No data sold to third parties.

Retention: 24 months (NDA term) + 6 years (Limitation Act 1980). Sanctions data: 5 years (MLR 2017 Reg. 40).

Transfers: UK/EEA only. If transferred, UK IDTA or SCCs apply per Art. 46.

Your rights: Access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), portability (Art. 20), objection (Art. 21). Contact: dpo@theNeobankers.group. Complaints: ico.org.uk.
Non-Disclosure Agreement ● UNREAD
Read Non-Disclosure Agreement 14 clauses · English law · LCIA
Electronic Signature

By activating this checkbox you: (i) execute this NDA electronically pursuant to Clause 14; (ii) confirm your professional investor status under MiFID II Annex II; and (iii) acknowledge the data processing described above. Governed by English law. LCIA arbitration, London.