A holding company for financial and digital infrastructure. Built on what it owns.

The NeoBankers Group Limited owns the architecture; licensed institutions provide the services. Everything else on this page follows from that division.

The Company is a private company incorporated in England and Wales on 30 December 2021, under company number 13821747. It is an independent holding company whose assets are not branches or customers but intellectual property: the Group’s trade marks, protocols, software and brands, and the architecture on which its projects are developed — the Integrated Digital Financial Ecosystem, IDFE™. It is a holding company in law and a steward of that architecture in practice.

The Group was founded by practitioners for practitioners. Its directors and leadership have spent their careers inside banking, asset management, payments and financial technology. They know how these systems work in practice, not only in theory, and they know from that experience where the cost, the delay and the exclusion in these services really come from: rarely from the services themselves, and far more often from the systems beneath them. The Group exists to rebuild those systems, and to leave the services to those who are authorised to provide them.

That is why the Group works with licensed institutions rather than in competition with them. A partner that builds on the Group’s architecture keeps its own customer relationships, its own regulatory obligations and its own decisions; what it gains is one architecture, decisions on the record, and a single point of accountability across the Group. Infrastructure may be global; accountability to regulators remains local.

The Group works across six areas of interest — financial infrastructure, digital assets, digital infrastructure, legal technology, the coordination of personal affairs and digital art — and in each it follows the same order of work: it designs the infrastructure first and develops projects on it second. The NeoBankers is a banking-technology project built on the IDFE™; it is not a bank, holds no banking licence and offers no financial services. MEETER™ is a protocol and messenger for confidential communication between independent systems. LawUp gives people a trusted route to independent legal professionals. Clé de Tout, with its application STEWARD, brings a person’s trusted advisers together around their affairs, with that person’s consent and under their control. ArtSky presents the work of the sculptor Oleg Pinchuk, with clear attribution and documented rights.

It follows that there are things the Company does not do, and it says so plainly. It is not a bank, a credit institution, an electronic money institution, a payment institution, a crypto-asset service provider, a fund or an asset manager. It is not authorised or regulated by the Financial Conduct Authority or the Prudential Regulation Authority. It does not accept deposits, hold client money or client assets, manage money or assets for others, or accept investments from the public, and it provides no services to clients. Any regulated activity connected with a Group project would be carried on only by an entity holding the required authorisation, in its own name.

The Company holds 99 per cent of the share capital of Neo Bankers sp. z o.o., a limited liability company incorporated in Poland. That company has been entered in the Polish Register of Virtual Currency Activities, under number RDWW-411, since 10 August 2022. The entry is a registration for anti-money laundering purposes, not a licence, and since 1 July 2026 the company has not provided crypto-asset services that require authorisation under the EU Markets in Crypto-Assets Regulation. The Group’s interests in other jurisdictions are held through separate companies, each answerable for its own conduct under its own law.

The Group does not aim to be the largest. It aims to be the one its partners and its people are proud to be associated with, and to be judged over years rather than seasons. The tabs that follow explain why it exists, how it thinks, what it values, how it is governed, how it works, what it owes to others and how it intends to give back.

Infrastructure that licensed institutions can rely on — built to outlast what is built on it.

In full, the Group’s purpose is to build the infrastructure on which licensed institutions can serve more people — more simply, more safely and at lower cost — and to hold it to a standard that outlasts the products built on it.

Every organisation can say what it does. Fewer can say why the world would be worse off without it. The Group’s answer begins with an observation that anyone who has worked inside a bank, a payment business or a law firm will recognise. Accounts that cannot speak to one another, settlement that waits for paperwork, professionals who cannot share what they know without exposing what they must protect — these are problems of infrastructure, and they are rarely solved by another product built on top of them.

So the Group builds the layer underneath. It does not serve the public directly, and it does not seek to replace the banks, payment institutions and professional firms that already do. They hold the licences, the relationships and the obligations that come with them. The Group’s work is to strengthen the existing system rather than to displace it: to give those institutions foundations that make their work simpler, safer and less costly to deliver, so that the benefit reaches the people they serve — including the many who are kept outside financial and professional services today by cost, complexity and paperwork rather than by any choice of their own.

Each part of the purpose carries a commitment. More people means designing from the start for those whom existing systems leave out, not adding them later. More simply means fewer steps, fewer intermediaries and plainer language. More safely means that security, the protection of personal data and the continuity of the service — its being there when it is needed — are conditions of the design rather than features of it. At lower cost means that efficiency is passed on to the institutions that use the infrastructure, and through them to the people they serve.

The last part of the purpose is the most demanding. Products change quickly; infrastructure must not. A standard that outlasts the products built on it is one that still holds when the applications on top have been replaced, the market has moved and the people who designed it have moved on. It is the reason the Group documents its decisions, publishes its principles and prefers open protocols to closed ones.

The Group states its purpose once, and uses it as a test. Before a project is taken on, it must show that it makes a licensed institution’s work simpler, safer or more accessible for the people that institution serves. A project that cannot show this is declined, however attractive it may be on other grounds — and the Group expects, from time to time, to turn down work that would have been profitable, on a question of principle. The same test guides the Board when it considers the long-term consequences of its decisions, as English company law requires of every director.

Purpose is, finally, a discipline of time. The Group plans for what its architecture will need long after the decision that created it, and it measures progress in years rather than announcements. That is how infrastructure earns trust: slowly, and by still being there.

Purpose says why the Group exists. Philosophy says how it builds — especially where no established model yet exists to follow.

Traditional finance and digital technology have spent the last decade alongside each other rather than together. One has the trust, the rules and the institutions; the other has the speed, the openness and the reach. The Group’s projects are conceived as architecture for what comes next: environments in which traditional and digital instruments are designed to work as one, rather than translated from one world into the other at every step.

No established term yet describes this combination, and the absence of a name is a responsibility as much as an opportunity. Where there is no precedent to lean on, standards must come from within. The Group therefore holds itself to institutional standards in the quality of its technology, the rigour of its approach to regulation and the clarity of its governance. Its underlying conviction is simple: financial and professional services should work for everyone, with safety as the starting requirement. And it holds that compliance cannot be added afterwards. Regulation is not an obstacle to be worked around but a design input to be understood from the first day; trust that is added later is rarely trusted.

The Group’s line — Re-engineering the Unchangeable — follows from that conviction. Many of the assumptions on which finance still runs were reasonable when they were made and have simply never been revisited. Re-engineering begins with a single question: why is it done this way? But it begins with understanding, not with impatience. The Group studies a system in detail before it proposes to change it, because only those who know why a process exists are entitled to remove it. Doing old things faster is not re-engineering. Rebuilding them so that they no longer need to be done at all is.

How the Group builds

The Group treats innovation as a method, not a feature. It designs technologies that remove friction from transactions and from the work of the professionals who carry them out, and its working rule is plain: a process that can be automated should be automated, and a step that can be eliminated should be eliminated.

That method only works if the foundations are shared, which is why the Group’s approach is architectural rather than product-led. Its projects rest on common foundations — the IDFE™ for financial projects and open protocols for communication projects — so that each new project builds on what already exists instead of starting again. Shared foundations are not meant to create dependence. The Group designs so that its partners grow stronger, not more reliant on it: open protocols, documented terms and the partner’s continued control of its own decisions are part of the architecture, not concessions to it.

Common foundations also mean common obligations. Digital financial and professional services should be open to as many people as possible, intuitive to use and resilient by design. Convenience and a high standard of security are not traded against each other; they are requirements to be met together, and an architecture that cannot meet both is not finished.

The Group is entrepreneurial in what it chooses to build and professional in how it builds it. It looks for what the market lacks and builds it properly. Where existing mechanisms fall short, it designs new ones and holds them to recognised industry standards. It is equally clear about what it will not build: it does not follow fashion or consensus for their own sake, it does not build products that depend on obscuring their cost or their risk, and it does not pursue scale that would outrun its ability to answer for what it has built.

Behind all of this sits a view of what the Group actually owns. Its assets are its architecture, its rights and its reputation. The first two can be rebuilt if they are lost; the third, in practice, cannot. Every decision is therefore taken as if the reputation of the whole Group depended on it — because, in infrastructure, it usually does.

These convictions come together in three words that the Group uses to test its own conduct.

Rigour. Humility. Partnership.

Rigour — the Group checks before it claims: considered, not hasty; coordinated, not isolated. In practice it records, it verifies and it corrects. Humility — the Group states what it is not, looks at facts dispassionately and owns its mistakes. In practice it listens, it says when it does not know and it gives credit where it is due. Partnership — the Group builds for those licensed to operate. In practice it documents terms, respects the boundaries of its partners’ obligations and stays for the long term. The three depend on one another: partnership counts for little without rigour, and rigour without humility becomes certainty — which infrastructure can never afford.

Values are what decide a question when the rules are silent. The Group holds six, grouped under the three words of its motto, and each is written as a commitment that can be checked against what it does.

Values are only worth stating if they change what an organisation does when a decision is difficult. Each value below therefore opens with a single line that can be held up against the Group’s conduct, followed by what it requires in practice. They apply equally to directors, employees and those who work with the Group; they are considered when people are appointed and when their work is reviewed; and the Code of Ethics sets out how they are upheld.

Rigour

1. Evidence before claims.

The Group states results only when it can show them.

It does not publish projections as achievements or describe work in progress as complete. When a claim cannot be supported, it says less rather than something it cannot defend. The same discipline applies inside the Group: a decision is only as good as the evidence on the record behind it.

2. Re-engineer, not repackage.

The Group builds new foundations rather than putting new labels on old ones.

Originality is not novelty for its own sake. An idea earns its place only when it solves a real problem better than what exists, and it is tested against reality before the Group speaks about it. Doing an old thing faster, or under a new name, is not the work the Group exists to do.

Humility

3. The person at the end of the chain.

Every design decision starts with the people who will rely on what the Group builds without ever seeing its name.

The Group does not serve those people directly, which makes the commitment more important, not less. Every design review begins with them: whether they can use what is built, understand it and trust it, whatever their means, their circumstances or their familiarity with technology. Accessibility is considered from the first sketch, in language as much as in code.

4. Integrity, without exception.

The Group does what it says, says what it does, and is candid about its limits.

When the right course is less convenient or less profitable, it takes it. When it gets something wrong, it says so first rather than waiting to be asked. And it is as precise about what it is not — not a bank, not regulated, not a holder of anyone’s money — as about what it is, because candour about limits is where trust begins.

Partnership

5. Partnership on the record.

The Group builds long-term partnerships on documented terms and shared standards.

It prefers fewer relationships that last to many that do not. It treats a partner’s regulatory obligations as its own concern rather than someone else’s problem, and it designs so that partners keep control of their own decisions. A partnership that cannot be written down plainly is not one the Group will enter.

6. Stewardship.

The Group looks after what others will inherit.

Infrastructure is held in trust for those who build on it. Protection, confidentiality and data protection are built in from the outset and are never traded away for convenience, because a weakness in infrastructure is never only the Group’s own: it is inherited by everyone who relies on it. Stewardship also reaches beyond the Group’s commercial work, to the communities it depends on — how the Group intends to contribute to them is set out under Philanthropy.

When values conflict

Values rarely conflict, but when they do the order of precedence is fixed in advance. The interests of the person at the end of the chain come first; the integrity of a partner’s regulatory position comes second; the Group’s own commercial interest comes last. Taken together, the six values describe a company that would rather be relied upon than admired.

Values describe what the Group believes. Principles describe how it is governed, so that those beliefs do not depend on the goodwill of any one person.

The Group’s governance can be stated in a few sentences before it is explained. The Company carries on no regulated activity. It keeps one record of its decisions. It discloses its related parties. Where two standards apply, it applies the stricter. No significant commitment rests on the decision of one person alone. The Group takes on work only where it can be of genuine use. And its principles are kept in the spirit as well as the letter, including when a matter is urgent — urgency is when standards are most often lowered, and it is never a reason to lower them.

Who decides what

The Company is governed by its Board of Directors in accordance with the Companies Act 2006 and its Articles of Association. The Board sets the Group’s direction, approves its policies, oversees its risks and is accountable for its conduct; matters reserved to the Board, including charitable contributions, are decided by the Board and recorded. Executive management carries those decisions into effect and reports to the Board. Each Group company is answerable for its own conduct under its own law, and any licensed partner remains answerable to its own regulator for the services it provides. The public register at Companies House is the authoritative record of the Company’s officers and filings.

The directors are under a legal duty, not merely a moral one, to act in the way they consider, in good faith, most likely to promote the success of the Company for the benefit of its members as a whole. In doing so they must have regard, among other matters, to the likely long-term consequences of their decisions, the interests of the Company’s employees, the need to foster its business relationships with suppliers, customers and others, the impact of its operations on the community and the environment, and the desirability of maintaining a reputation for high standards of business conduct, as section 172 of the Companies Act 2006 requires. The Group treats this duty as the frame within which every significant decision is taken. Directors also carry responsibilities beyond those of everyone else: to set the example, to hear concerns, and to check decisions rather than merely approve them.

The regulatory boundary

The clearest of the Group’s principles concerns the boundary of what it does. The Company carries on no regulated activity. Any regulated activity connected with a Group project would be carried on only by an entity holding the required authorisation, in its own name, under the supervision of its own regulator. Where a Group company is registered with a supervisory authority, it deals with that authority openly and promptly. The boundary is reflected in how the Group describes itself, in its contracts and on this website, and it is stated in the same words wherever it appears. More broadly, the Group seeks constructive dialogue with those its work affects — its partners and the communities in which it works — and, where invited, with the authorities that supervise its partners.

Transparency and conduct

Related-party relationships and transactions are disclosed as the applicable accounting framework requires and are reviewed by the Board. The Company files its accounts, confirmation statements and other statutory filings with Companies House as the law requires. The Group’s intellectual property is held and protected at holding-company level, so that the rights on which partners rely sit with one owner and are not dispersed. The way decisions are prepared, taken and recorded, and the mechanisms that protect the Group’s rights, are built into its internal procedures, so that governance acts as the Group’s conscience in small decisions as well as large ones. The Company’s contracts are governed by the law of England and Wales.

The Group does not tolerate bribery or corruption in any form, by anyone acting on its behalf. Its conduct is set out in a framework of published policies that apply across the Group as a minimum: the Code of Ethics; the Anti-Bribery and Corruption, Anti-Money Laundering and Sanctions, and Conflicts of Interest Policies; the Whistleblowing and Complaints Policies; the Supplier Code of Conduct and the Modern Slavery Statement; and the Privacy and Cookie Policy and the Information Security Statement. These policies bind everyone who works for the Group, and where a Group company is subject to stricter local requirements, the stricter standard applies. Anyone unsure how a policy applies is expected to ask before acting, not after.

Principles are kept current by review rather than by assumption. The Board keeps these principles, the policies that give effect to them and the Group’s purpose and values themselves under review, and updates them when the Group’s activities, the law or its risks change. The date shown at the head of this page is the date of the version in force.

Culture is not what a company says about itself. It is what it rewards, what it tolerates and what it corrects when no one outside is watching.

The Group is small, and its culture is set by a few people working closely together. That is an advantage and a responsibility. At this size no one is peripheral, the distance between a good idea — or a real concern — and the people who decide is short, and status counts for less than the quality of an argument. It also means that habits formed now will become the way the Group works when it is larger. Growth will change the Group’s size; it is not meant to change its standards. What follows is the standard it holds itself to. Some of it is already practice; some of it is still being earned, and the Group would rather say so than pretend otherwise.

The Group is shaped by what it practises every day, which is why it attends to habits rather than to slogans.

The first habit is writing things down. Decisions, the assumptions behind them and the moments when someone changed their mind are recorded, so that the reasoning survives the people who made it. Every decision has one named owner, so that responsibility is never shared so widely that no one holds it. For an infrastructure company this is not bureaucracy; it is the only way a partner, an auditor or a future colleague can understand why something was built the way it was. A useful test is whether someone outside the Group could follow the reasoning from the record alone.

The second habit is checking before claiming. Nothing is described as done, tested or proven until it has been, and it is always acceptable to say “I do not know”. An honest gap is more useful than a confident guess, because a guess in infrastructure is inherited by everyone who builds on it. Seniority is no exemption: a decision taken at the top is checked as carefully as any other, and those who check it are thanked for doing so.

Disagreement is expected, and it belongs in the room. People start from the assumption that their colleagues mean well, and they argue with the reasoning, not with the person. Before a decision everyone is asked to test it; once it is taken, everyone is asked to carry it out. A problem that reaches the surface is treated as information rather than as blame. A mistake is never concealed, and when something goes wrong the Group looks for the cause rather than the culprit, so that a problem solved once does not return. A standard is not relaxed for a single exception, and never because a matter is urgent.

None of this is meant to make the work joyless. People are treated with dignity and respect, including when mistakes are made. The Group prefers collegiality to competition between colleagues, it expects people to work at a pace they can sustain, and it believes that work done carefully and well should be a source of satisfaction to those who do it. Credit, like responsibility, is given accurately: work is attributed to those who did it, inside the Group and outside it, including partners, advisers and the artists and authors whose work the Group presents.

The Group is a workplace, not a platform for causes. As a company it takes no part in political campaigns; its people remain free to hold and express their own views in their own name.

From these habits it is easy to see what the Group rewards and what it does not tolerate. It rewards rigour over speed, candour over comfort, and work that makes the next person’s job easier. It does not tolerate misrepresentation of results, discrimination, harassment, retaliation against anyone who raises a concern, or conduct that would embarrass the Group if it were reported accurately.

A culture is only as strong as the safety of those who test it. If something does not seem right, the Group expects people to say so. Anyone who works with the Group — a director, an employee, a contractor or a supplier — may raise a concern with any director or in confidence through the Whistleblowing channel, without fear of reprisal, and every concern raised in good faith is heard.

In responsibility, as in business, the Group measures practical benefit, not gestures. What it builds today is the infrastructure others will rely on tomorrow.

The Group is precise about the scope of its responsibility, because claiming too much is as misleading as claiming too little. Its direct responsibility covers three things: what it designs, how it runs its own operations, and whom it chooses to work with. Responsibility for the services built on its architecture rests with the licensed institutions that provide them, under the supervision of their own regulators. Within that scope, the Group holds itself to commitments it can be measured against, not to claims of results already achieved.

For every stakeholder the first question is integrity: how the Group manages its relationships, its risks and its own standards. It is the condition of its licence to operate. Two cornerstones support everything else. The first is compliance: the Group complies with the laws in force, through precautions built into its structures and processes rather than added afterwards. The second is risk management, for which the Board bears overall responsibility. The Board sets the Group’s approach to responsibility, including under the ESG and Environmental Policy; executive management carries it out and reports on it.

Through what the Group builds

An infrastructure company’s first responsibility is to its infrastructure. Those who build on the Group’s architecture must be able to rely on it being secure, available when it is needed and recoverable when something fails, and the Group designs so that no partner depends on a single point of failure — including the Group itself. Protection of personal data and confidentiality are built in from the outset.

The second responsibility is access. The Group’s view is practical, and it rests on four commitments. Access by design: projects are designed to lower the cost, complexity and paperwork that keep people outside financial and professional services. Plain language: the Group writes plainly, and expects the same of any provider of a service built on its projects. Measured claims: the Group publishes facts about its impact only where it can evidence them. Consistent standards: the Group’s policies apply across its companies as a minimum.

Access matters most where it is missing. A large share of the world’s adults still has no account with a financial institution, and many more are poorly served by the accounts they have. The Group’s financial projects are designed with that gap in mind: fewer steps, clearer language and lower barriers to entry. Financial literacy is the other half of access, and the Group intends to contribute to it through plain-language publications in Insights and, in time, through partnerships with educational organisations. Any such programme will be described here only once it has begun.

As a company

As a holding company that owns rights rather than operating services, the Group’s own environmental footprint and supply chain are limited, and it does not pretend otherwise. What it can do, it does: it favours efficient systems — lightweight pages, no third-party scripts without consent, and fonts hosted with the website rather than loaded from third parties — and it does not describe itself as “green”, “carbon-neutral” or “sustainable” without independent evidence. The Group sees a close link between sustainable development and its ability to innovate and to create value that lasts. Its work has regard to the United Nations Sustainable Development Goals most relevant to it: decent work and economic growth; industry, innovation and infrastructure; reduced inequalities; and peace, justice and strong institutions.

The Group respects and supports human rights, and its responsibility extends to the people it never meets: those who make the goods and provide the services it buys. Its expectations of suppliers are set out in the Supplier Code of Conduct, the Modern Slavery Statement and the Human Rights and Equal Opportunities Policy, and they apply to every relationship regardless of size.

A company is only as strong as the communities it works in, and infrastructure may be global while accountability remains local. Where the Group contributes to those communities beyond its commercial work, it does so under the principles set out in Philanthropy. It welcomes views on its approach through the general enquiry form.

The Group intends philanthropy to be part of how it works, not an afterthought. Practical benefit comes first: contributions will be chosen for what they achieve, not for how they look.

The Group’s responsibility to society is expressed first in the ethics and integrity of how it does business, then in the personal involvement of its people, and only then in giving — which it keeps discreet. A company that builds infrastructure for the long term has an obligation that reaches beyond its partners and its shareholders. Taking a long-term view means being accountable to the next generation as well as the current one, and the Group’s approach to giving starts from that idea rather than from a budget or a calendar.

“The Group does not presume to solve financial exclusion on its own. It seeks to build infrastructure that makes inclusion easier — and to hold itself to the standards that make that infrastructure trustworthy.”

Matvei Hutman, Group Chief Executive Officer

Its focus, once contributions begin, follows from its work and from what it knows. Financial education, because access to financial services means little without the confidence to use them, and because explaining finance plainly is part of the Group’s own discipline. Digital inclusion, because the services of the future will be digital, and no one should be left outside them for want of a device, a skill or a connection — the same barriers the Group designs against. Children’s rights, because the next generation is the one to which the Group is ultimately accountable. And youth sport, not at the elite level but where it begins, because it teaches earlier than any classroom the discipline, fairness and teamwork on which every institution depends.

How the Group gives

The Group treats each contribution as a partnership with the organisation that receives it, not as a transaction. It would rather make a small number of serious, multi-year commitments than many small gifts, and it aims to strengthen the organisations it supports — their capacity and their ability to sustain their work — rather than to fund a gesture. Where its people’s knowledge is more useful than money, it intends to give that too: help with plain-language explanation, with secure and accessible technology, and with the governance of the organisation itself.

Contributions will be made through established organisations working close to the people they serve, in the places where Group companies work, and chosen for the difference they make on the ground, so that the Group contributes to the wider development of the regions in which it works. The Group does not accept unsolicited requests for donations or sponsorship; it selects the organisations it supports through its own research and network, and supports them by invitation. Every charitable contribution is made only with the approval of the Board and is recorded, as the Anti-Bribery and Corruption Policy requires. The Group makes no political contributions.

The Group conducts this work quietly, and by deliberate choice. It prefers to let the work speak for itself; this page therefore sets out the principle rather than the particulars.

A future foundation

The Group has not established a foundation. If the Board decides to establish one, the terms on which it would be constituted are fixed now, before any funds are committed, so that the foundation’s independence does not depend on the circumstances in which it is created.

A foundation would be a charitable entity separate from the Company, governed by its own trustees, a majority of whom would be independent of the Group’s executive management. Trustees would serve without remuneration and would decide grants at their own discretion within the focus areas set out above. The Company would approve appointments to the board but would not direct the foundation’s work, which would be led by a director accountable to the trustees. Its assets would be held for charitable purposes only and could never return to the Group. Any commitment of funds to it would be a decision of the Board, recorded in the same way as every other charitable contribution. As an alternative to a free-standing charity, the Board may instead establish a dedicated fund administered by an established independent foundation, on the same terms.

Its limits would be as clear as its purpose. It would not fund individuals; political parties, campaigns or causes; organisations in which a director or a related party has a personal interest; or any activity that would confer a commercial advantage on the Group. It would make a small number of significant commitments rather than many small ones, it would follow the same rule on unsolicited requests, it would publish its guidelines when it begins its work, and it would report as charity law requires.

Philanthropy, in the end, is the most direct test of the Group’s values. It is where stewardship stops being a word on a page and becomes a decision — taken quietly, recorded properly and judged by its results.