Modern Slavery Statement

Financial Year 2024/2025

Introduction

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that Model Group Finance Ltd (Company No. 15830292) has taken to ensure that modern slavery and human trafficking are not taking place in our business or supply chains.

Our Business

Model Group Finance is a UK-based financial technology company authorized by the Financial Conduct Authority (FCA Firm Reference: 900507). We provide:

  • International money transfer services
  • Multi-currency accounts
  • Virtual payment cards
  • Business banking solutions

Our registered office is at 128 City Rd, London EC1V 2NX, United Kingdom.

Our Commitment

Model Group Finance is committed to acting ethically and with integrity in all our business dealings and relationships. We have a zero-tolerance approach to modern slavery and human trafficking. We are committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

Our Supply Chains

Our supply chains include:

  • Technology and software service providers
  • Payment processing and banking partners
  • Identity verification and compliance services
  • Cloud infrastructure and hosting providers
  • Customer support and contact center services
  • Professional services (legal, audit, consulting)

Due Diligence & Risk Assessment

We conduct due diligence on all our suppliers and business partners to assess and manage the risk of modern slavery. Our approach includes:

  • Supplier Screening: All new suppliers undergo screening for modern slavery risks
  • Contractual Requirements: Our contracts include clauses requiring suppliers to comply with modern slavery legislation
  • Regular Reviews: We conduct periodic reviews of our key suppliers and their practices
  • Risk Assessment: We assess suppliers based on geography, industry sector, and nature of services

Policies & Procedures

We have implemented the following policies and procedures to prevent modern slavery:

  • Code of Conduct: Sets out ethical standards expected from all employees and suppliers
  • Whistleblowing Policy: Enables employees to report concerns confidentially
  • Recruitment Policy: Ensures fair and ethical hiring practices
  • Supplier Code of Conduct: Requires suppliers to maintain ethical labor practices

Training & Awareness

We provide training to our employees to help them identify and report potential instances of modern slavery. This includes awareness of red flags such as signs of physical or psychological abuse, restricted movement, withheld documents, and poor living conditions.

Measuring Effectiveness

We measure the effectiveness of our efforts through:

  • Number of suppliers screened for modern slavery risks
  • Completion rates for employee training programs
  • Number of concerns raised through our whistleblowing procedure
  • Regular audits of high-risk suppliers
  • Feedback from employees and suppliers

Reporting Concerns

If you have concerns about modern slavery in our business or supply chains, please report them to:

  • Email: compliance@modelgroupfinance.com
  • Whistleblowing Line: +44 20 1234 5679
  • Address: Compliance Department, Model Group Finance Ltd, 128 City Rd, London EC1V 2NX, UK

All reports will be treated confidentially and investigated thoroughly.

Continuous Improvement

We are committed to continuously improving our practices to combat modern slavery. We will review this statement annually and update it as necessary to reflect changes in our business and best practices.

Board Approval

This statement has been approved by the Board of Directors of Model Group Finance Ltd.

Signed: [Board Director Name]

Title: Chief Executive Officer

Date: October 6, 2025