Governed by its Board. Accountable on the record.

The Board is collectively responsible for the long-term success of the Company. It sets the Group’s strategy, approves its policies, oversees risk and holds the leadership to account. The directors’ duties are those set out in sections 171 to 177 of the Companies Act 2006, including the duty to promote the success of the Company for the benefit of its members as a whole.

The Board has three directors. It has not established committees; all matters are considered by the full Board. A small Board means decisions can be taken quickly and on the record. Everyone at the Group is responsible for managing risk; the Board bears overall responsibility for risk, and day-to-day application rests with the Executive Committee. As the Group grows, the Board intends to consider establishing audit and risk, and remuneration and nomination, committees.

The Company’s governance framework provides for board committees, but none has been formed at present. Until then, the full Board of three directors retains responsibility for risk, information security and financial-crime matters. When committees are formed, they will be listed here with their remit and reporting lines.

Separation of roles. The shareholders exercise their rights under the Companies Act 2006 and the Articles of Association; the Board sets direction and oversees; the Executive Committee manages the Group day to day.

The Company’s verified registration details — name, number, date and place of incorporation, former name, registered office, nature of business, directors, person with significant control and subsidiary — are set out in Corporate facts.

Corporate documents. The Articles of Association and the full filing history are public at Companies House: filing history of Company No. 13821747.

The mark ® is not used on this website because no trade mark is yet registered. The mark ™ indicates a name the Company uses as a trade mark.

Not every risk can be eliminated. The Board decides which risks the Group is prepared to accept, and which it is not. Risk and compliance are treated as part of the design of the business and as conditions of operating, not as later additions.

• Sanctions — the Group does not deal with persons subject to sanctions imposed by the United Kingdom, the European Union, the United Nations, the United States or Switzerland. Counterparties are screened before a relationship begins, and records are kept for five years.
• Anti-money laundering — the Company is not within the regulated sector under the Money Laundering Regulations 2017. It nevertheless applies risk-based due diligence to its counterparties under its AML and Sanctions Policy, and the offences in the Proceeds of Crime Act 2002 apply to it in full.
• Bribery — the Anti-Bribery and Corruption Policy is designed as an adequate procedure under section 7 of the Bribery Act 2010.
• Data protection — personal data is processed under UK GDPR, EU GDPR and the Swiss revFADP.

The Board approves the Group’s policies and reviews them at least annually — and as the law changes, not only on a schedule. Each policy is published with its version and date, in four groups: Legal Notice and Terms; Privacy and Data; Ethics and Integrity; Responsible Business. The Modern Slavery Statement and the Tax Strategy are published voluntarily. The full list is in the footer of every page.

What each document is for

• Legal Notice and Terms (last updated 3 August 2026) — who operates the website, what the Group is and is not, and the terms of use.
• Risk Factors (last updated 27 October 2026) — the principal risks of the Group’s direction.
• Accessibility Statement (last updated 3 August 2026) — how the website can be used by everyone, and how to ask for another format.
• Complaints Policy (last updated 3 August 2026) — how a complaint is received, investigated and answered.
• Privacy and Cookie Policy (last updated 3 August 2026) — what personal data is collected, why, and your rights.
• Data Retention Schedule (last updated 3 August 2026) — how long each kind of record is kept.
• Candidate Privacy Notice (last updated 3 August 2026) — how applicants’ data is handled.
• Business Continuity Statement (last updated 27 October 2026) — how the Company prepares for and recovers from a significant disruption.
• Information Security Statement and Vulnerability Disclosure Policy — how security is managed and how to report a weakness.
• AI use (last updated 26 October 2026) — where AI is and is not used.
• Code of Ethics (last updated 3 August 2026) — the standards of conduct expected of everyone acting for the Group.
• Anti-Bribery and Corruption Policy (last updated 3 August 2026) — zero tolerance of bribery, gifts and hospitality rules.
• AML and Sanctions Policy (last updated 3 August 2026) — counterparty checks and sanctions screening.
• Conflicts of Interest Policy (last updated 3 August 2026) — how conflicts are declared and managed.
• Whistleblowing Policy (last updated 3 August 2026) — how to raise a concern in confidence.
• Human Rights and Equal Opportunities Policy (last updated 3 August 2026) — respect for human rights and equal treatment.
• Modern Slavery Statement (last updated 3 August 2026) — steps against slavery and trafficking in the supply chain.
• Supplier Code of Conduct (last updated 3 August 2026) — what the Group expects of its suppliers.
• ESG and Environmental Policy (last updated 3 August 2026) — the Group’s environmental, social and governance commitments.
• Tax Strategy (last updated 3 August 2026) — how the Group manages its tax affairs.

Banks, partners and suppliers carrying out due diligence on the Group may request, through Regulatory and compliance in Enquiry channels:

• the certificate of incorporation, the change-of-name certificate and a current register extract;
• the Articles of Association;
• the register of persons with significant control and the identity-verification status of the directors;
• the Group structure register, the Intellectual property register and the KRS extract of the subsidiary;
• the sanctions screening statement;
• the policies listed in the footer.

Requests are acknowledged within five business days. Banks and counterparties: see For banks and counterparties.

Compliance in practice.

• Policies are adopted by the Board, each with a review date.
• Concerns can be raised through the Regulatory and compliance form or under the Whistleblowing Policy, without fear of retaliation.
• Built around the rules — not around them. Compliance was not added after the fact: the Group’s architecture is designed around the rules that will apply to the operators who use it.
• Each policy is reviewed at least once a year.
• What the Company has said it will do, and where each item stands: Commitments and progress.
• The Group makes no political donations and does not use politicians or lobbyists to represent it; any political activity of its people is kept separate from their work for the Group.
• Concerns about accounting, internal controls or audit can be raised through the Regulatory and compliance form, marked “Accounting”.

Compliance goes without saying. We still write it down.

The compliance risks the Group manages:

• data protection and confidentiality — Privacy and Cookie Policy;
• money laundering and terrorist financing, and sanctions — AML and Sanctions Policy;
• bribery — Anti-Bribery and Corruption Policy;
• conflicts of interest, including personal trading by directors and staff — Conflicts of Interest Policy.

Memberships. The Company is not a member of any trade association at present.

Compliance areas. For the Group, compliance is the minimum; the aim is controls that actually work.

• Anti-financial crime — AML and Sanctions Policy and Anti-Bribery and Corruption Policy;
• Tax compliance — Tax Strategy;
• Data protection — Privacy and Cookie Policy;
• Conduct — Code of Ethics and Conflicts of Interest Policy.

Fresh ideas, yes — but evolution, not revolution, in how the Group is run. Each proposal is weighed, tested and, where needed, slept on before the Board decides. Even non-standard work follows a written checklist, so every specialist involved works from the same list. The Group learns from setbacks as well as successes, and writes the lessons down.

• Constitution — the Company is governed by its Articles of Association adopted on 5 February 2026, which are filed at Companies House.
• Shares and votes — the Company has two classes of ordinary shares: Class A shares carry three votes each and Class B shares one vote each; both rank equally for dividends and capital.
• The Board — decisions are taken by the directors collectively at Board meetings or by written resolution, as the Articles provide.
• Matters reserved to the Board — the Group’s strategy and annual plan; the creation, acquisition, licensing or disposal of intellectual property; the establishment, acquisition or disposal of Group companies; entry into material contracts and partnerships; the approval and annual review of policies; the approval of the annual accounts; charitable contributions.
• Conflicts — directors declare interests before a matter is considered (Companies Act 2006, ss.175, 177 and 182) and do not take part in decisions in which they have a conflict.
• Records — decisions are minuted, including the place of the meeting, and kept with the statutory records.

See also: Ethics and integrity · Corporate facts · Trust and registrations