The Neobankers Group Limited

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

We are building it.

Financial-Investment Holding Company Pioneering Innovation in Digital Finance

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

Our Company

The Neobankers Group is an independent, international, multidisciplinary holding group based in the United Kingdom, with decades of experience in business consulting, private advisory, fintech, blockchain, IT, and regulatory services.

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

Our core business areas are the innovative services designed to protect and grow our clients' wealth. With the support of qualified partners, we offer service coverage to companies and entrepreneurs worldwide.

The Group develops innovative financial solutions for consumers, small businesses, corporations, and institutions. Whether serving customers, helping small businesses, or working with partners — we identify issues and propose solutions that propel the future and strengthen both our clients and our communities.

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 a feature. It is how we build.

We develop products and technologies that remove friction from financial transactions — whether classical payments or blockchain. Every process that can be automated is automated. Every step that can be eliminated is eliminated.

Our focus is accessibility. Digital financial services should be available to everyone — intuitive, seamless, and secure by design. Convenience and comfort at the highest level of security is not a trade-off. It is the standard.

We think in architectures, not products. A single transaction platform that bridges fiat and digital assets, designed from the ground up for speed, reliability, and institutional trust.

At its foundation are five core values that define the Group's culture and guide every decision.

Put Clients First
Every product, every service, and every decision begins with the client's interest.
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, not replicate what exists.
Diversity & Inclusion
Financial services for everyone. No barriers, no complexity, no exclusion.
Give Back
We strengthen our clients and our communities. Growth is shared.
Security
Convenience never comes at the cost of safety. The highest level of protection is the default.
  • The Group is governed by its Board of Directors in accordance with the Companies Act 2006.
  • Directors act in the interest of the Company and its shareholders.
  • The Company does not itself conduct regulated financial services activity.
  • Related-party relationships are disclosed.
  • 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.
Our Philosophy

We do not fit into an existing category. We are 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 classical payments and blockchain transactions are indistinguishable to the user. Where automation replaces manual process at every level. Where accessibility, comfort, and security are not in tension with each other but are one and the same.

There is no established term for what we are building because the market has not yet seen it built. We are the pioneers defining this space.

The Neobankers Group is committed to maintaining a first-class standard of service and excellence that defines the Group. We will continue to break new ground in advising, serving, and providing new opportunities for our clients.

Our conviction is simple: financial services must work for everyone. No barriers, no complexity, no compromise on safety. That is the standard we set for every product and every technology we develop.

Business Direction
Payments
E-money solutions, multi-currency accounts, SEPA, SWIFT, card programmes
Digital Assets
Custody, exchange, OTC, tokenisation, blockchain infrastructure
BaaS
White-label infrastructure, embedded finance APIs, compliance-as-a-service
Token Economy
Fiat-backed electronic money tokens, RWA tokenisation, collateralised lending
IT & Technology
Software development, platform engineering, system architecture, IT consulting
Licensing & Regulatory Advisory
Regulatory strategy, compliance framework design, licensing pathway consulting, jurisdictional analysis
Leadership Team
Dr Reinis Tumovs
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
Vladimir Vardzielov
Jacob Mitbreit
Group COO
Co-Owner
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, seamless 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
Thesis
IDFE: A Category Without a Name
Why the Integrated Digital Financial Ecosystem belongs to a market segment that is only now taking shape — and why no established term yet exists for it.
Perspective
The Convergence of Payments and Blockchain
Classical payment instruments and distributed ledger transactions are moving toward a single infrastructure. The question is no longer whether, but when.
View
Automation as Prerequisite, Not Feature
Every manual step in a financial transaction is a point of failure. We believe the next generation of financial services will automate by default.

IMPORTANT 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. 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, or an offer to sell or a solicitation to buy any security, financial instrument, or service. 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 forward-looking statements. Information on this website is subject to change without notice. This website is governed by the laws of England & Wales. 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 –-

← 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

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 –-

← 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

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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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.

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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

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Personal Identification
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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.
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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.