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 and covers that company only. It is made 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.

Concerns about child labour or conflict minerals in the Group’s supply chain can be reported through the Whistleblowing channel.

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 company limited by shares 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:

• Professional services: legal advisory, accounting, regulatory consulting, and tax advisory.
• Technology services: software development, cloud infrastructure (IaaS/PaaS), IT consulting, and cybersecurity services.
• Corporate services: serviced office facilities, telecommunications, 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:

• Code of Ethics: requires all persons associated with the Group to 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.
• Whistleblowing Policy: provides a confidential reporting channel for 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.

The Company works with professional and technology suppliers in the United Kingdom and the European Union. It considers its own risk of modern slavery to be low, and checks this at every new supplier relationship. It will not work with any organisation that has been, or is found to be, knowingly involved in modern slavery, and it will promptly and fully investigate any concern brought to its attention.

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