Modern Slavery Statement

Modern Slavery Statement 2026

This statement sets out the steps taken by Unitylink Financial Services Limited ("the Firm") to identify, assess, and mitigate the risk of modern slavery and human trafficking within its business operations and supply chains. This statement is prepared in accordance with section 54(1) of the UK Modern Slavery Act 2015 and is governed by the laws of England and Wales.

Introduction

The Firm is committed to maintaining effective systems and controls to prevent modern slavery and human trafficking in its operations and supply chains. This statement outlines the Firm's approach to managing these risks and demonstrates its commitment to ethical conduct and regulatory compliance.

Our Business

Unitylink Financial Services Limited is a UK-based digital money remittance provider operating under the Unitylink brand. Headquartered in London, the Firm facilitates international money transfers for customers located in the United Kingdom to recipients in overseas jurisdictions.

Governance, Values and Policies

The Firm maintains a zero-tolerance approach to modern slavery and human trafficking. It is committed to conducting its business with integrity, in accordance with applicable laws, regulations, and regulatory expectations.

This commitment is supported by a framework of internal policies and procedures, including but not limited to:

• Whistleblowing procedures, which enable employees and associated persons to raise concerns confidentially and without fear of retaliation;
• Anti-Bribery and Corruption Policy, which establishes standards for ethical conduct and the prevention of financial crime; and
• Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) policies, which include requirements to identify and report suspicious or unethical activity.

All employees and contractors are required to adhere to these policies and are expected to act with integrity, exercise appropriate judgment, and promptly escalate any concerns relating to potential unlawful or unethical conduct.

Supply Chain Risk Management

The Firm seeks to ensure that modern slavery and human trafficking are not present within its business or supply chains. It does not knowingly engage with, or support, any organisation involved in such practices and will take appropriate action, including termination of relationships, where credible concerns are identified.

The Firm's suppliers include financial institutions, telecommunications providers, and remittance partners operating across multiple jurisdictions. A risk-based due diligence process is applied to suppliers and partners, which includes:

• Assessment of regulatory status and compliance frameworks;
• Financial crime due diligence, including AML and CTF controls;
• Adverse media screening, including checks for allegations or evidence of modern slavery or human trafficking.

Ongoing Monitoring and Continuous Improvement

The Firm is committed to continuously improving its approach to managing modern slavery risks. This includes ongoing monitoring of the effectiveness of its controls, periodic review of policies and procedures, and enhancement of due diligence processes where appropriate.

Training

The firm provides training to all staff on modern slavery and human trafficking, alongside other mandatory compliance programmes such as AML/CTF and Anti-Bribery and Corruption.

The firm remains committed to strengthening its approach by increasing awareness and ensuring employees are well equipped to identify and respond to risks related to modern slavery and human trafficking. This commitment is supported by the continuous improvement of internal processes, enhanced due diligence, and ongoing alignment with industry best practices.