Modern Slavery and Human Trafficking

Our Commitment

Redbanx Ltd (“Redbanx”, “we”, “us”) is committed to preventing modern slavery and human trafficking in all aspects of our business and supply chain.

We take a zero-tolerance approach to all forms of modern slavery, including forced labour, human trafficking, exploitation and any form of coercion. We are committed to acting ethically, with integrity and transparency in all business relationships, and to implementing effective systems and controls to safeguard against these risks.

This statement is made in accordance with the requirements of the UK Modern Slavery Act 2015.

Our Business

Redbanx is a UK-based, Financial Conduct Authority-regulated Electronic Money Institution providing payment services, foreign exchange solutions and account services to a global client base.

Our operations are primarily digital and supported by a network of regulated financial institutions, technology providers and operational partners.

Our Supply Chains

Our supply chains are focused on regulated and professional service providers and include:

• Banking partners and safeguarding institutions (including ClearBank Limited)
• Payment processors and liquidity providers
• Technology providers (including onboarding, screening and transaction monitoring systems)
• Professional services (legal, audit and consultancy)
• Facilities and corporate service providers

We recognise that, while our sector is generally considered lower risk, we remain vigilant to the potential for modern slavery risks within our supply chain.

Our Policies and Controls

Redbanx maintains a robust framework of policies and controls designed to prevent modern slavery and human trafficking, including:

• Anti-Slavery and Human Trafficking Policy – setting out our commitment to ethical conduct and zero tolerance for exploitation
• Whistleblowing Policy – enabling employees and stakeholders to raise concerns confidentially and without fear of retaliation
• Anti-Money Laundering and Financial Crime Policies – supporting the identification of suspicious or exploitative activity
• Supplier Due Diligence and Outsourcing Framework – ensuring third parties meet appropriate ethical and regulatory standards

We are committed to maintaining a workplace that is respectful, inclusive and free from any form of forced or exploitative labour. All employees are subject to fair recruitment processes, right-to-work checks and clear contractual terms.

Due Diligence and Risk Management

Redbanx applies a risk-based approach to managing modern slavery risk, including:

• conducting due diligence on relevant suppliers and partners
• assessing financial crime and ethical risk as part of onboarding and ongoing monitoring
• incorporating contractual obligations requiring compliance with applicable laws and ethical standards
• reviewing supplier relationships on an ongoing basis

Where risks are identified, appropriate mitigation actions are taken.

Training and Awareness

Employees involved in procurement, onboarding and risk management are provided with training to ensure awareness of modern slavery risks and how to identify and escalate concerns.

Training forms part of our broader financial crime and compliance programme.

Monitoring and Effectiveness

Redbanx monitors the effectiveness of its controls through ongoing oversight, internal governance and periodic review of policies and procedures.

We remain committed to continuously improving our approach to preventing modern slavery and human trafficking.

Board Approval

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and constitutes Redbanx’s modern slavery and human trafficking statement.

This statement has been approved by the Board of Directors of Redbanx Ltd.