Modern Slavery and Human Trafficking Statement

September 2025

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and sets out the steps Valegro Pay Ltd has taken, and continues to take, to ensure that modern slavery and human trafficking are not taking place within our business or our supply chains.

Our Business

Valegro Pay Ltd is a financial technology company providing secure payment solutions for businesses and individuals. We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or supply chains.

Our Commitment

We have a zero-tolerance approach to modern slavery and human trafficking. We are committed to ensuring transparency in our operations and expect the same high standards from all of our contractors, suppliers, and other business partners.

Policies in Relation to Modern Slavery

Valegro Pay Ltd has implemented policies to support our commitment, including:

• Ethical business conduct and compliance with all applicable laws.
• Responsible recruitment practices to ensure all employees work voluntarily.
• Supplier standards requiring compliance with human rights and labour laws.
• Whistleblowing procedures that allow concerns to be raised confidentially.

Risk Assessment and Due Diligence

We recognize that the greatest risks of modern slavery may arise within our supply chains. To address this, we:

• Conduct due diligence checks on suppliers, particularly those in higher-risk sectors or jurisdictions.
• Require suppliers and contractors to adhere to our ethical standards.
• Review contracts and procurement processes to ensure compliance.

Training and Awareness

We provide training and guidance to employees to help them identify and respond to risks of modern slavery. We ensure that relevant staff members, particularly those involved in procurement and supplier management, are aware of the signs of exploitation and how to report concerns.

Monitoring and Continuous Improvement

We are committed to continuous improvement in preventing modern slavery and human trafficking. We will regularly review and update our policies, procedures, and training to strengthen our approach.

Approval

This statement has been approved by the Director of Valegro Pay Ltd and will be reviewed annually.