Modern Slavery and Human Trafficking Statement

This statement is made pursuant to Section 54(1) of the UK Modern Slavery Act 2015 and constitutes the Modern Slavery and Human Trafficking Statement for Luno Group Holdings Limited (“LGHL”) and its qualifying subsidiaries (collectively, "Luno" or "the Group") for the financial year ending 31 December 2025.

This statement provides an overview of our business, and the steps taken to mitigate the risks of slavery and human trafficking in our supply chains and business operations. 

1. Statement of Commitment and Board Approval

Luno is committed to upholding the highest standards of ethical conduct and corporate governance. As a business dedicated to building a more open and equitable financial system, we maintain a zero-tolerance approach to all forms of modern slavery, forced labor, and human trafficking within our business operations and supply chains.  

This statement details the steps Luno has taken during the financial year to mitigate against the risk of modern slavery taking place in any part of our business or supply chains.  

2. Our Business, Structure and Supply-Chains

2.1 Our Organisation

LGHL is the UK-incorporated parent company of the Luno group of companies, which consists of a number of operating and service companies globally.

2.2 Our Supply Chain

Luno's supply chain focuses predominantly on intangible services rather than the manufacturing of physical goods. Our supply chain is categorised into the following key areas:  

• Financial and Payment Services: Third-party financial institutions and payment processors necessary for platform operations.

• Technology Infrastructure: Providers of critical services such as cloud computing, data center operations, and IT infrastructure. The majority of our third-party vendors provide software and technology services, which are generally considered low-risk for modern slavery and human trafficking. However, we recognise upstream activities, such as hardware manufacturing and data centre construction, may carry elevated risks. Where relevant, we seek to engage established and reputable suppliers and apply proportionate due diligence to mitigate these risks. 

• Professional and Corporate Services: Providers of legal, accounting, consulting and other essential business support services.

• Office and Ancillary Services: Suppliers providing services for our physical offices, such as cleaning, catering, security, and building maintenance. These services are acknowledged as higher-risk for labour exploitation in certain jurisdictions. To that end, we endeavour to engage the services of reputable suppliers and apply proportionate due diligence measures to mitigate these risks.

3. Risk Assessment and Unique Sector Risks

3.1 Supply Chain Risk Profile

Luno’s supply chain is primarily composed of software, technology, and professional service providers; sectors generally considered low-risk for modern slavery. We acknowledge peripheral risks in ancillary services (e.g. cleaning, security) and address these through robust procurement controls. Our due diligence processes include risk-based onboarding, contractual safeguards, and periodic reviews to ensure standards are upheld.

3.2 Combating Financial Crime and Platform Misuse Risk

A unique and material risk within financial services is the potential for services to be exploited by perpetrators of modern slavery and human trafficking for the purposes of money laundering and other illicit financial transactions. Luno recognises that fighting modern slavery is intrinsically linked to our Anti-Money Laundering (“AML”) and Know Your Customer (“KYC”) compliance programs. Our dedicated Anti-Financial Crime Compliance team leverages technology, including machine learning and data analytics, to proactively detect suspicious transactions that may be indicative of trafficking activities. Where suspicious financial activity that could be linked to human trafficking is detected, it is escalated and reported accordingly. In this way, we mitigate the risk of Luno’s services being used for illicit financial transactions related to human trafficking.

4.  Policies and Governance

To prevent and mitigate modern slavery risks, Luno has implemented a formal framework of internal policies and standards, based on the principles of the United Nations Guiding Principles on Business and Human Rights and the International Labour Organisation’s Core Conventions. 

These include:  

• Business Ethics and Conduct: This formal, board-approved policy outlines our commitment to ethical business relationships and the enforcement of effective systems and controls.  

• Vendor Risk Management Policy This Policy governs our supply chain due diligence processes and actions. We apply a risk-based approach to third-party due diligence, focusing on factors such as country risk, sector risk, and the nature of the products/services provided. In addition, enhanced due diligence is conducted on high-risk third parties and, where necessary, this also extends to right-to-audit clauses, on-site inspections, documentary proof of labour standards, and obligations for suppliers to cascade these requirements to their subcontractors. 

• Global Whistleblowing Channels: We provide independent, secure, and confidential mechanisms for employees and contractors to report any suspected instances of wrongdoing, including modern slavery or human trafficking, with non-retaliation protection explicitly stated. Suppliers and service providers are also provided with a confidential means to report any concerns, via Luno's website. 

• Recruitment and Employment Policies: Our internal employment policies are designed to ensure fair labor practices, adherence to local labor laws, proper "right to work" checks, and checks to ensure all employees are above the minimum working age.  

6. Key Performance Indicators (KPIs)

The effectiveness of our various compliance efforts and initiatives is monitored against specific key performance indicators (KPIs) which are used to drive continuous improvement.  

7. Training and Awareness

Luno ensures that employees receive appropriate training on modern slavery and human trafficking risks. Mandatory e-learning modules are established for all staff, with enhanced, role-specific training provided to employees in high-risk functions, including:  

• Procurement and Third-Party Risk Management;

• Human Resources; and

• Anti-Financial Crime and Compliance teams.

This training educates employees on the appropriate internal and external channels for reporting suspicious activity. Role-specific scenario-based workshops and management briefings are provided annually for high-risk functions. Training completion rates are monitored and reported.

This statement has been approved and signed by James Lanigan, Director of LGHL.