Modern Slavery & Human Trafficking Statement for the Fianellas Group

A. INTRODUCTION
Fianellas is committed to continuously improving its practices to ensure that slavery and human trafficking do not occur in any part of our business. We expect the same commitment from our suppliers, contractors, and partners.
This statement outlines the steps Fianellas has taken to meet the requirements of the Modern Slavery Act 2015 (UK) and the Australia Modern Slavery Act 2018 (Cth). This statement was approved by the Board of Directors of Fianellas on 18 September 2024, on behalf of itself and the second reporting entity covered by the statement, Fianellas Australia Pty Ltd, whose parent company is Fianellas.

B. ORGANISATIONAL STRUCTURE
Fianellas is a public company incorporated in the United Kingdom and is the ultimate holding company of the reporting entity, Fianellas Payments Ltd. Fianellas Australia Pty Ltd ("Fianellas Australia") is registered in Australia and is a wholly-owned subsidiary of Fianellas. Additionally, Fianellas has subsidiaries in various countries worldwide, as outlined in Appendix 1 (collectively referred to as the "Fianellas Group").
The primary activity of the Fianellas Group is to provide our customers with new ways to manage money internationally, including sending and receiving funds abroad.

Each month, we process more than £10 billion globally and operate across 30 offices worldwide. Our team currently includes over 6000 employees. Our operations are not seasonal, nor do we engage in sectors identified by the UK government as having a higher risk of modern slavery, such as construction, food and drink, resources and mining, or retail.
As the ultimate parent entity within the Fianellas Group, the Fianellas Board is responsible for ensuring that policies and procedures are aligned across all entities.
This statement was prepared based on input and consultation from various teams within the Fianellas Group, including Legal, Third Party Management, Compliance, Privacy, and Risk.

C. OUR APPROACH TO SLAVERY AND HUMAN TRAFFICKING
Fianellas is committed to ensuring that no modern slavery or human trafficking exists within our supply chains or any part of our business. We act with integrity and a strong ethical commitment in all business relationships and have implemented effective systems to prevent slavery and human trafficking throughout our operations and supply chains.
We support the ten principles of the United Nations Global Compact, which focus on human rights, labor, the environment, and anti-corruption, and fully endorse the global agenda to abolish human trafficking, slavery, and forced, compulsory, and child labor.

D. OUR SUPPLY CHAINS AND RISK ASSESSMENT
The Fianellas Group relies on an extensive supply chain to power our business and serve our customers. We intend to manage all current and future third-party relationships with these anti-slavery principles in mind. We will not knowingly support or conduct business with any suppliers involved in slavery.

Our suppliers support us in a wide range of areas, including recruitment, compliance, marketing, technology, card production, facilities management, and banking. We also maintain relationships with central banks and payment infrastructure services to efficiently operate our business and advance our Mission.
The majority of our suppliers are based in the UK, the EU, and North America.

In addition to conducting initial due diligence on new suppliers, as outlined below, we periodically reassess our suppliers to ensure they continue to be the best fit for our needs. A dedicated team performs risk assessments on third parties during the onboarding process, frequently re-evaluates risks, and reviews the Fianellas Group supply chain. This team also communicates to key potential suppliers that we have a zero-tolerance policy regarding slavery and makes it clear that Fianellas intends to conduct business free from modern slavery.

Throughout this reporting period, we conducted an analysis of our supply chains and operations. During this assessment, local operations managed by our direct employees posed the lowest risk. Currently, our highest risk area involves offshore labor arranged by third-party providers.

E. DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our commitment to identify and mitigate risks, Fianellas Group has established processes to identify and assess potential risk areas within Fianellas and our supply chains, as well as to evaluate the effectiveness of these actions. These processes include:

• Conducting due diligence on new third parties, including a review of materials, which also incorporates an assessment of whether the supplier or its supply chain has a heightened risk of modern slavery. During the due diligence process, we inquire if the Modern Slavery Act applies to the supplier and, if so, request supporting evidence of their Modern Slavery Act statement to review the steps they have taken to prevent modern slavery in their business and supply chains.
• Monitoring potential risk areas in our supply chains by periodically reviewing our relationships with suppliers in proportion to their overall risk level to the Fianellas Group.
• Setting high standards for the work we do and the conduct expected from our employees. We have a Code of Conduct that sets out minimum expectations for all Fianellas employees. We emphasize empathy and adherence to our values, fostering an open, supportive culture where employees can thrive, perform at their best, and feel empowered to raise concerns they may have about our business or suppliers. We clearly define unacceptable behavior to ensure we protect the culture we have built.
• Protecting whistleblowers through our Whistleblower Policy, which provides a confidential channel for whistleblowers to anonymously submit disclosures if they choose, ensuring their identity remains protected.

Fianellas will not support or conduct business with any entity known to be involved in slavery or human trafficking.

F. SUPPLIER ADHERENCE TO COMPANY VALUES
Fianellas upholds a zero-tolerance policy toward slavery and human trafficking. To ensure that all parties within Fianellas's supply chain and contractors align with our values, we have established a supply chain compliance program. This program includes a thorough due diligence process, as previously mentioned, to assess the potential risk of slavery and human trafficking for new third parties, including materials.

G. TRAINING AND POLICIES
To foster an understanding of the risks associated with modern slavery and human trafficking within our supply chains and across our business, Fianellas has implemented training, ethics, disciplinary, and whistleblowing policies and procedures.
These policies and procedures encourage Fianellas employees to raise any concerns and empower Fianellas to take corrective actions if necessary, including those related to slavery or human trafficking.

H. ONGOING ASSESSMENT
Each year, our senior management assigns a review of the effectiveness of the processes we have in place across the Fianellas Group to assess and address the risks of modern slavery and human trafficking.

I. MEASURING EFFECTIVENESS
In alignment with the Modern Slavery Act 2015 (UK) and the Australian Modern Slavery Act 2018 (Cth), Fianellas measures the effectiveness of our anti-slavery and anti-trafficking efforts through the following:

• Annual reviews of the Modern Slavery Statement; effective deployment of internal training, whistleblowing policies and procedures, ethics, and disciplinary actions.
• Standard and enhanced due diligence procedures for third parties working with Fianellas.
• Risk assessments of each new outsourcing arrangement, which include modern slavery risk evaluations.
• Ongoing management and monitoring of Fianellas supply chains.
• Implementation of controls through the maintenance of Fianellas's internal third-party management system.