ESG and 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.

As an IP holder without offices or data centres of its own, the Group’s direct footprint is small; most of its impact lies in the infrastructure its projects will run on. Where the Group is not a signatory to a recognised initiative, it says so, and follows its main principles where relevant.

2. Environmental Commitment

Environment is everyone’s business. 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:

• Minimising energy consumption in its operations and selecting, where commercially practicable, hosting and infrastructure providers that utilise renewable energy sources or maintain carbon-neutral certifications.
• Reducing paper usage through digital-first documentation, electronic signatures, and paperless client communications.
• Considering the environmental impact of its supply chain and service providers, and incorporating sustainability criteria into procurement decisions on a risk-proportionate basis.
• Monitoring and, where practicable, reporting on the Group's carbon footprint as operations scale.
• Supporting the development of blockchain technologies that adopt energy-efficient consensus mechanisms, including proof-of-stake and comparable protocols.

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:

• Designing financial products and infrastructure that promote financial inclusion, particularly for underserved and excluded populations worldwide.
• Maintaining transparent fee structures and clear client communications in plain language, to enable informed decision-making.
• Fostering a diverse and inclusive workplace, where recruitment, advancement, and compensation are determined by merit, qualifications, and performance, without discrimination on the basis of any protected characteristic under the Equality Act 2010.
• Upholding a zero-tolerance policy against modern slavery, human trafficking, and forced labour, as set out in the Group's Modern Slavery Statement published pursuant to section 54 of the Modern Slavery Act 2015.
• Conducting supplier and counterparty due diligence on a risk-proportionate basis, with particular attention to labour standards, human rights, and sanctions compliance.
• Contributing, through its commercial operations and regulatory standards, to the broader objective of financial system integrity and consumer protection.

4. Governance Commitment

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

• Board oversight of strategy, risk management, and compliance, with directors acting in accordance with their duties under the Companies Act 2006.
• Disclosure of related-party relationships and transactions in accordance with IAS 24 and the Group's Conflicts of Interest Policy.
• A zero-tolerance anti-bribery and anti-corruption policy under the UK Bribery Act 2010, with a section 7 adequate procedures defence maintained by the Board.
• Robust anti-money laundering and sanctions compliance frameworks, as set out in the Group's AML and Sanctions Policy.
• An independent complaints procedure and a confidential whistleblowing channel, as set out in the Group's Complaints Policy and Whistleblowing Policy respectively.
• A transparent tax strategy, published voluntarily in the spirit of the Finance Act 2016.
• Periodic review of all governance policies by the Board, with annual review cycles.

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 Task Force on Climate-related Financial Disclosures (TCFD).
• The Global Reporting Initiative (GRI).
• The UN Principles for Responsible Investment (PRI), where applicable to the Group's investment activities.

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 partners, 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.the General enquiry form.

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.