Environmental, Social, and Governance
(ESG) Policy
Last Updated: December 1, 2025
Our Commitment to Sustainable Finance
At Unicorn Currencies, we believe that financial services companies have a responsibility to operate sustainably, inclusively, and ethically. While we don't manufacture products or operate physical infrastructure at scale, we recognize that every business—including digital-first fintech platforms—has an impact on the environment, society, and the governance of the financial system.
Our ESG Policy outlines our commitment to conducting business in a manner that creates value for our clients, employees, partners, and communities while minimizing negative environmental impact, promoting social inclusion and equity, and upholding the highest standards of governance and ethical conduct.
Our ESG strategy is built on three pillars: Environmental Efficiency, Social Inclusion, and Governance Excellence.
Alignment with Global Frameworks
Our ESG approach aligns with internationally recognized frameworks and standards:
United Nations Sustainable Development Goals (SDGs)
We contribute to the achievement of multiple UN SDGs:
SDG 8: Decent Work and Economic Growth - Providing fair employment, supporting SME growth through accessible financial services
SDG 9: Industry, Innovation, and Infrastructure - Leveraging technology to build inclusive financial infrastructure
SDG 10: Reduced Inequalities - Democratizing access to institutional-grade treasury services for underserved businesses
SDG 12: Responsible Consumption and Production - Paperless operations and efficient use of digital resources
SDG 13: Climate Action - Minimizing our carbon footprint through digital-first operations and remote work
SDG 16: Peace, Justice, and Strong Institutions - Combating financial crime, corruption, and promoting transparent governance
Additional Frameworks
Task Force on Climate-related Financial Disclosures (TCFD) - Transparency on climate-related risks and opportunities
UN Guiding Principles on Business and Human Rights - Respecting human rights throughout our operations and value chain
Global Reporting Initiative (GRI) - Comprehensive sustainability reporting standards
ISO 26000 Social Responsibility - Guidance on socially responsible business conduct
PILLAR 1: ENVIRONMENTAL RESPONSIBILITY
Our Environmental Philosophy
As a digital-first treasury platform, Unicorn Currencies operates with a minimal physical footprint. We don't manufacture goods, operate factories, or maintain fleets of vehicles. Our environmental impact stems primarily from energy consumption (data centers, office operations) and business travel.
Our strategy: Maximize operational efficiency through digitalization, leverage carbon-efficient infrastructure, and minimize unnecessary resource consumption.
1.1 Paperless Operations: Eliminating Physical Waste
Challenge: Traditional foreign exchange and trade finance operations generate significant paper waste through physical documentation, contracts, compliance files, and transaction records.
Our Solution:
Digital KYC and Client Onboarding:
100% digital client onboarding process eliminating physical application forms, identity documents, and supporting paperwork
Electronic identity verification through our Verify365 platform using secure digital document uploads and biometric verification
Digital storage of all KYC documentation in secure, encrypted cloud repositories
Impact: Each client onboarding that would traditionally require 20-50 pages of printed documentation is now completed entirely digitally
Electronic Signatures and Contracts:
All client agreements, contracts, and transaction confirmations executed via secure electronic signature platforms (DocuSign, Adobe Sign)
Master Services Agreements, forward contract confirmations, and compliance documentation signed digitally
Legal validity ensured through compliance with eIDAS (EU), ESIGN Act (USA), and PIPEDA (Canada)
Impact: Elimination of printing, physical mailing, and storage of thousands of pages of contracts annually
Digital Transaction Confirmations and Reporting:
All transaction confirmations, account statements, and regulatory reports delivered electronically via email and client portal
Real-time access to transaction history, statements, and reporting through secure online platforms
Elimination of monthly printed statements and physical correspondence
Impact: Thousands of pages of transactional documents delivered digitally per year
Cloud-Based Document Management:
Secure cloud storage of all client records, transaction documents, and compliance files
Elimination of physical file cabinets, storage facilities, and paper archives
Advanced search, retrieval, and retention management through digital document management systems
Impact: Zero physical document storage requirements; 7-year regulatory retention periods managed entirely digitally
Environmental Benefits:
Paper Reduction: Estimated elimination of 10,000+ pages of paper annually (and growing with client base)
Reduced Transportation Emissions: No courier services or postal deliveries required for document exchange
Office Space Efficiency: No physical storage requirements, reducing office space needs and associated energy consumption
Forest Conservation: Contribution to reducing demand for paper production and associated deforestation
1.2 Carbon-Efficient Cloud Infrastructure
Challenge: Data centers traditionally consume significant energy and contribute to carbon emissions. On-premise infrastructure requires dedicated cooling, redundant power systems, and physical hardware.
Our Solution:
Partnership with Carbon-Efficient Cloud Providers:
We leverage cloud infrastructure from providers committed to carbon neutrality and renewable energy:
Amazon Web Services (AWS):
AWS's commitment to powering operations with 100% renewable energy by 2025
Use of AWS regions powered by renewable energy sources where available (e.g., Canada, Ireland, Oregon)
AWS's water-positive and circular economy initiatives minimizing environmental impact
AWS's energy-efficient custom silicon (Graviton processors) reducing energy consumption per compute unit
Supabase and PostgreSQL Infrastructure:
Cloud-native architecture built on energy-efficient modern data centers
Database optimization reducing unnecessary compute and storage overhead
Efficient query processing and caching minimizing energy-intensive operations
Infrastructure Efficiency Practices:
Right-Sizing: Continuous optimization of compute resources to match actual needs, avoiding over-provisioning
Auto-Scaling: Dynamic scaling of resources based on demand, reducing idle capacity and associated energy waste
Serverless Architecture: Use of serverless functions (AWS Lambda) that consume resources only when actively processing requests
Data Lifecycle Management: Automated tiering of data storage (hot, warm, cold, archive) ensuring infrequently accessed data is stored on energy-efficient storage classes
Compression and Deduplication: Data compression and deduplication techniques reducing storage footprint and energy consumption
Comparison to On-Premise Alternative:
If Unicorn Currencies operated on-premise data centers, we would require:
Physical servers with 24/7 cooling and power systems
Redundant infrastructure for disaster recovery
Significant energy consumption for compute, storage, and cooling
Physical space, construction materials, and ongoing maintenance
By operating in the cloud, we leverage shared infrastructure achieving economies of scale and benefiting from cloud providers' investments in renewable energy and efficiency—environmental benefits we could not achieve independently as a small organization.
Environmental Benefits:
Reduced Carbon Footprint: Estimated 80-90% reduction in carbon emissions compared to on-premise infrastructure (based on cloud provider sustainability reports)
No Physical Hardware Waste: No electronic waste from decommissioned servers; hardware lifecycle managed by cloud providers with recycling programs
Scalability Without Waste: Ability to scale operations without proportional increase in physical infrastructure or energy consumption
1.3 Remote-First Workforce: Minimizing Commuting Emissions
Challenge: Traditional office-based work requires daily commuting, contributing significantly to urban traffic congestion, air pollution, and carbon emissions.
Our Solution:
Global Remote-First Operating Model:
Unicorn Currencies operates a distributed, remote-first workforce with team members across:
Canada (Surrey, Toronto, Vancouver)
United Kingdom (London, Manchester)
United Arab Emirates (Dubai)
India (Mumbai, Bangalore, Delhi)
Remote Work Infrastructure:
Cloud-based collaboration tools (Slack, Zoom, Google Workspace) enabling seamless remote teamwork
Secure VPN and access controls ensuring data security for remote employees
Digital-first processes eliminating need for physical office presence (paperless operations, electronic signatures, cloud-based systems)
Flexible work arrangements supporting work-life balance and reducing unnecessary travel
Commuting Emissions Avoided:
Calculation Example (approximate):
Average daily commute: 20-30 km round trip (varies by city)
Average emissions: 0.12-0.15 kg CO₂ per km (passenger vehicle)
Daily emissions per employee: ~3-4 kg CO₂
Annual emissions per employee (220 working days): ~650-880 kg CO₂
For our team of 20 employees operating remotely instead of commuting:
Estimated annual commuting emissions avoided: ~13,000-17,600 kg CO₂ (13-17.6 metric tons)
Equivalent to: Removing 3-4 passenger vehicles from the road for a year
Additional Benefits:
Reduced Urban Congestion: Contribution to reducing traffic congestion in major cities
Improved Air Quality: Reduction in local air pollution (NOx, particulate matter) associated with vehicle emissions
Employee Wellbeing: Time saved from commuting (1-2 hours per day) improves work-life balance, reduces stress, and enhances productivity
Access to Global Talent: Ability to hire the best talent regardless of location, promoting diversity and inclusion
Business Travel Management:
When business travel is necessary (client meetings, regulatory engagements, team offsites), we:
Prioritize virtual meetings where feasible
Consolidate travel to maximize value per trip
Select direct flights and fuel-efficient transportation options
Consider carbon offset programs for unavoidable travel (future initiative)
1.4 Energy Efficiency in Office Operations
For our small physical office spaces (serviced offices and co-working spaces):
Use of energy-efficient LED lighting
Selection of Energy Star-rated office equipment
Power management settings on computers and devices
Preference for serviced offices with green building certifications (LEED, BREEAM) where available
Recycling programs for office waste and electronic equipment
1.5 Future Environmental Initiatives
As we grow, we commit to:
Carbon Footprint Measurement: Conducting comprehensive Scope 1, 2, and 3 carbon footprint assessments by 2026
Carbon Neutrality Roadmap: Developing a roadmap to achieve carbon neutrality by 2030 through emissions reductions and carbon offset programs
Sustainable Procurement: Incorporating environmental criteria into vendor selection (prioritizing suppliers with strong environmental credentials)
Client Impact Measurement: Helping clients understand the environmental benefits of digital treasury management compared to traditional paper-based processes
Green Finance Products: Exploring opportunities to support clients' sustainable business practices through trade finance for green industries or preferential rates for certified sustainable businesses
PILLAR 2: SOCIAL RESPONSIBILITY
Our Social Philosophy
Financial services have historically been gatekeepers, often excluding small and medium enterprises, minority-owned businesses, and underserved communities from accessing sophisticated treasury tools. Unicorn Currencies exists to democratize access, promote inclusion, and create economic opportunity for businesses that traditional banks have overlooked.
Our strategy: Expand access to institutional-grade financial services, build a diverse and inclusive organization, and uphold the highest labor and human rights standards.
2.1 Financial Inclusion: Democratizing Treasury Services
Challenge: Small and medium-sized enterprises (SMEs), particularly those engaged in international trade, face significant barriers in accessing foreign exchange and treasury management services:
High Minimums: Traditional banks and FX brokers impose high minimum transaction sizes (often £100,000+) excluding smaller businesses
Complex Onboarding: Lengthy, bureaucratic onboarding processes favoring large corporations
Lack of Technology: Legacy systems without modern APIs, mobile access, or real-time reporting
Geographic Limitations: Limited service in emerging markets or for businesses trading with non-traditional corridors
Opacity: Opaque pricing with hidden spreads and fees disadvantaging unsophisticated clients
Our Solution:
Accessible Transaction Minimums:
Low or no minimum transaction sizes enabling SMEs to access professional FX services regardless of volume
Flexible service models accommodating businesses at various stages of growth
Streamlined Digital Onboarding:
100% digital KYC process completable in days, not weeks
User-friendly application designed for business owners without dedicated treasury teams
Multilingual support and translated documentation for non-English speakers
Institutional-Grade Technology for SMEs:
Modern client portal with real-time rates, transaction execution, and reporting
API integrations enabling automation and connection to accounting/ERP systems
Mobile accessibility for business owners managing treasury on the go
Transparent, Fair Pricing:
Clear disclosure of exchange rate spreads and fees (no hidden costs)
Competitive pricing accessible to smaller businesses (rates previously available only to large corporations)
No surprise correspondent bank charges or complex fee structures
Global Reach:
Support for 50+ currencies and payments to 150+ countries
Expertise in emerging market corridors and non-traditional trade routes
Partnerships with local payment networks (SEPA, SWIFT, ACH) ensuring reliable delivery
Educational Support:
Resources and guidance helping SMEs understand foreign exchange risk, hedging strategies, and treasury best practices
Dedicated account managers providing consultative support, not just transactional service
Webinars, guides, and tools empowering businesses to make informed decisions
Impact:
By serving SMEs and underserved businesses, Unicorn Currencies contributes to:
Economic Growth: Enabling SMEs to expand internationally, hire employees, and contribute to GDP growth (SDG 8: Decent Work and Economic Growth)
Trade Facilitation: Reducing friction in cross-border trade, supporting global supply chains (SDG 9: Industry, Innovation, and Infrastructure)
Entrepreneurship: Empowering entrepreneurs and business owners with tools to compete globally
Reduced Inequality: Leveling the playing field between large corporations and smaller businesses in accessing financial services (SDG 10: Reduced Inequalities)
Client Profile: Our typical client is a small-to-medium importer/exporter, e-commerce merchant, or professional services firm conducting international business—precisely the segment often ignored or underserved by traditional banks.
2.2 Diversity, Equity, and Inclusion (DEI)
Challenge: The financial services industry has historically lacked diversity, particularly in leadership roles. Women, ethnic minorities, and other underrepresented groups face barriers to entry and advancement.
Our Commitment:
Minority-Led Leadership:
Nazia M Thakur, Founder & CEO, and Mohsen M Thakur, Co-Founder & COO, bring diverse perspectives and lived experiences as minority leaders in fintech
Leadership representation setting the tone for an inclusive culture throughout the organization
Global, Diverse Workforce:
Our team reflects the global, multicultural nature of our client base:
Geographic Diversity: Team members across 4 continents (North America, Europe, Middle East, Asia)
Cultural Diversity: Representation of multiple nationalities, languages, and cultural backgrounds
Gender Diversity: Commitment to achieving gender balance across all levels of the organization
Linguistic Diversity: Multilingual team supporting clients in English, French, Punjabi, Hindi, Urdu, Arabic, and other languages
Inclusive Hiring Practices:
Recruitment from diverse talent pools, including underrepresented communities and non-traditional backgrounds
Structured interview processes reducing unconscious bias
Skills-based assessments focusing on capabilities, not pedigree
Remote-first model enabling access to global talent regardless of location, family obligations, or physical ability
Equitable Compensation and Development:
Fair, transparent compensation policies with regular pay equity reviews
Equal access to training, mentorship, and advancement opportunities
Flexible work arrangements supporting caregivers, individuals with disabilities, and employees with diverse needs
Zero tolerance for discrimination, harassment, or retaliation
Supplier Diversity (Future Initiative):
Commitment to sourcing from minority-owned, women-owned, and small businesses where feasible
Evaluation of vendor diversity as part of procurement decisions
Impact:
Our DEI commitment creates:
Innovation: Diverse teams bring varied perspectives, enhancing problem-solving and innovation
Client Understanding: A diverse workforce better understands and serves our diverse, global client base
Economic Opportunity: Creating quality jobs and career pathways for underrepresented groups
Role Modeling: Demonstrating that fintech leadership can and should reflect the diversity of the communities we serve
2.3 Fair Labor Practices and Human Rights
Challenge: Global supply chains, particularly in technology and services, are vulnerable to labor exploitation, modern slavery, and poor working conditions.
Our Commitment:
Strict Labor Standards:
Fair Wages: All employees paid at or above National Minimum Wage / Living Wage standards in their jurisdictions
Working Conditions: Compliance with working time regulations, rest periods, and paid leave entitlements
Safe Environment: Commitment to health and safety in all work environments (physical and remote)
Freedom of Association: Employees' rights to organize, join unions, or engage in collective bargaining fully respected
Modern Slavery and Human Trafficking:
We are committed to ensuring that modern slavery and human trafficking do not exist in our business or supply chains:
Modern Slavery Statement: Voluntary publication of Modern Slavery Statement in accordance with UK Modern Slavery Act 2015 (www.unicorncurrencies.com/modern-slavery-statement)
Supply Chain Due Diligence: Rigorous due diligence on suppliers and business partners, particularly technology vendors, to ensure ethical labor practices
Contractual Protections: All third-party contracts include modern slavery compliance clauses and audit rights
Training: Staff training on recognizing signs of modern slavery and exploitation
Human Rights Throughout the Value Chain:
UN Guiding Principles on Business and Human Rights: Commitment to respecting human rights throughout our operations, products, and relationships
Data Protection Rights: Safeguarding client and employee data privacy as a fundamental human right (GDPR, PIPEDA compliance)
Financial Inclusion as a Right: Recognition that access to financial services is increasingly recognized as essential for economic participation and human dignity
Zero Tolerance for Exploitation:
No forced labor, child labor, or any form of human trafficking in our operations or supply chain
Immediate termination of relationships with any supplier found to engage in exploitative practices
Cooperation with law enforcement in investigating and prosecuting labor violations
2.4 Community Engagement and Social Impact
Client Education and Empowerment:
Free educational resources (webinars, guides, articles) helping SMEs understand FX markets, risk management, and treasury best practices
Thought leadership on regulatory developments (sanctions, AML) impacting international trade
Support for first-time importers/exporters navigating the complexities of cross-border payments
Industry Collaboration:
Participation in fintech industry associations and working groups advancing financial inclusion
Advocacy for proportionate regulation that protects consumers while enabling innovation serving underserved markets
Contribution to public policy discussions on SME access to finance, trade facilitation, and financial crime prevention
Charitable Giving (Future Initiative):
As the company achieves profitability and scale, commitment to allocating a portion of profits to charitable causes aligned with our mission (financial literacy, entrepreneurship support, refugee economic integration)
PILLAR 3: GOVERNANCE EXCELLENCE
Our Governance Philosophy
Strong governance is the foundation of trust in financial services. Clients, regulators, employees, and partners must have confidence that Unicorn Currencies operates with integrity, transparency, accountability, and respect for stakeholder rights.
Our strategy: Implement robust governance structures, leverage ethical AI, maintain zero tolerance for corruption, and ensure Board-level oversight of ESG risks.
3.1 Ethical AI and Responsible Technology
Challenge: Artificial intelligence and machine learning systems, while powerful, can perpetuate bias, lack transparency, and infringe on privacy if not carefully governed.
Our Approach:
AI and Automation Use Cases at Unicorn Currencies:
Optical Character Recognition (OCR): Extracting data from identity documents during KYC verification
Risk Scoring: Assessing client risk profiles based on multiple data points for AML/CTF compliance
Transaction Monitoring: Detecting patterns indicative of suspicious activity or financial crime
Fraud Detection: Identifying anomalies suggesting fraud, identity theft, or account takeover
Customer Service Automation: Chatbots and automated responses for common inquiries
Principles of Ethical AI:
1. Transparency and Explainability:
Clients have the right to understand when AI is being used in decisions affecting them
Risk scores and compliance decisions based on AI models are reviewable by human compliance officers
Material AI-driven decisions (account denials, relationship terminations) are explained to clients with opportunities for human review and appeal
We avoid "black box" AI systems where decision logic is opaque and unexplainable
2. Fairness and Non-Discrimination:
Bias Testing: AI models are regularly tested for discriminatory bias based on protected characteristics (race, ethnicity, gender, age, nationality, religion)
Training Data Quality: Training datasets are reviewed for representativeness and historical biases
Fairness Metrics: Model performance is evaluated across demographic groups to identify disparate impact
Human Oversight: High-stakes decisions (account closures, large transaction blocks) require human review to catch algorithmic errors or bias
3. Privacy and Data Protection:
Data Minimization: AI systems use only the minimum data necessary for their intended purpose
Purpose Limitation: Data collected for one purpose (e.g., KYC) is not repurposed for unrelated AI applications without consent
Encryption and Security: Training data and model outputs are encrypted and access-controlled
Compliance with GDPR/PIPEDA: Automated decision-making complies with data protection regulations including rights to explanation and human review (GDPR Article 22)
4. Accountability and Governance:
AI Governance Committee: Cross-functional oversight of AI systems including Compliance, Technology, Legal, and Risk
Model Validation: Independent validation of AI models by third-party auditors or internal audit
Incident Response: Procedures for responding to AI errors, bias incidents, or unintended consequences
Continuous Monitoring: Ongoing performance monitoring and retraining to maintain accuracy and fairness over time
5. Human-in-the-Loop:
AI is used to augment, not replace, human judgment in critical decisions
Compliance officers review AI-generated alerts and scores before taking action
Clients can request human review of AI-driven decisions affecting their access to services
Final accountability for decisions remains with human decision-makers, not algorithms
Specific Safeguards:
KYC and Identity Verification:
OCR technology extracts data from identity documents, but human compliance officers review results for accuracy and conduct final verification
Biometric matching scores are supplemented by manual review to prevent false rejections
Individuals denied due to identity verification failures can provide alternative documentation or request manual review
Risk Scoring and AML:
Risk scores are transparent inputs to human decision-making, not automatic determinants of service access
Scoring models are calibrated to avoid over-weighting factors correlated with protected characteristics (e.g., nationality, ethnicity)
Clients can request explanations of their risk ratings and provide additional context or documentation
High-risk ratings trigger enhanced due diligence and human review, not automatic denial
Transaction Monitoring:
AI-powered monitoring generates alerts for human investigation; alerts are not automatically escalated to suspicious activity reports
Alert thresholds are tuned to minimize false positives while maintaining effective detection
Clients whose transactions are delayed for review are informed and provided with status updates
Future Commitments:
Publication of AI Ethics Statement outlining detailed principles and governance (by 2026)
Regular AI bias audits and public reporting of fairness metrics (commencing 2027)
Client education on how AI is used in our services and their rights to human review
3.2 Anti-Corruption and Financial Crime Prevention
Challenge: Bribery, corruption, and financial crime undermine trust, distort markets, and harm societies.
Our Commitment:
Zero Tolerance for Corruption:
Unicorn Currencies maintains a zero tolerance policy for bribery, corruption, and financial crime, as detailed in our comprehensive policies:
Anti-Bribery and Corruption (ABC) Policy: Strict compliance with UK Bribery Act 2010 and Canadian Corruption of Foreign Public Officials Act (CFPOA) - www.unicorncurrencies.com/abc-policy
Key Prohibitions:
No bribes, kickbacks, or improper payments to government officials, clients, or business partners
No facilitation payments, even in jurisdictions where they are culturally accepted
No gifts or hospitality exceeding $100 without prior approval
No political contributions by the company
No tolerance for fraud, false accounting, or concealment of corrupt payments
Robust Financial Crime Controls:
Financial Crime Prevention Framework: Comprehensive AML/CTF program with three lines of defense, advanced technology (sanctions screening, transaction monitoring), and rigorous KYC/KYB processes - www.unicorncurrencies.com/financial-crime-prevention
Regulatory Compliance:
FINTRAC registration and compliance with Canadian AML/CTF regulations
Alignment with FCA standards through authorized partners
Strict adherence to sanctions programs (OFAC, OFSI, UN, EU, Canada)
Suspicious activity reporting to financial intelligence units (FINTRAC, NCA)
Governance and Oversight:
Board-level oversight of compliance and financial crime risks
Independent Compliance function with authority to block transactions or terminate relationships
Annual internal and external audits of AML/CTF program effectiveness
Mandatory staff training on anti-bribery, AML, and sanctions compliance
Whistleblower Protection:
Confidential reporting channels for suspected corruption or financial crime (ethics@unicorncurrencies.com)
Zero tolerance for retaliation against whistleblowers - www.unicorncurrencies.com/whistleblower-policy
Encouragement of speak-up culture where concerns are raised without fear
3.3 Data Protection, Privacy, and Cybersecurity
Challenge: Financial services companies handle sensitive client data, making data protection and cybersecurity governance critical to trust.
Our Commitment:
Data Protection Governance:
Comprehensive Privacy Policy compliant with UK GDPR and PIPEDA - www.unicorncurrencies.com/privacy
Data Protection Officer / Privacy Officer responsible for data governance and regulatory compliance
Privacy by Design: Embedding data protection into product development, system architecture, and business processes
Regular Data Protection Impact Assessments (DPIAs) for new products, systems, or data processing activities
Client rights: Access, rectification, erasure (subject to regulatory retention requirements), restriction, portability, and objection
Cybersecurity Governance:
Encryption: All data encrypted at rest (AES-256) and in transit (TLS 1.2+)
Access Controls: Role-based access controls (RBAC) and multi-factor authentication (MFA) for systems accessing client data
Security Monitoring: 24/7 security monitoring, intrusion detection, and incident response capabilities
Penetration Testing: Regular third-party penetration testing and vulnerability assessments
Vendor Security: Rigorous security assessments of all technology vendors (SOC 2, ISO 27001 certifications required)
Incident Response: Documented incident response plan with procedures for breach notification to regulators and affected clients
Compliance Certifications and Standards (Roadmap):
SOC 2 Type II certification (target: 2026)
ISO 27001 Information Security Management System certification (target: 2027)
PCI DSS compliance (if/when payment card processing is introduced)
3.4 Board Oversight and ESG Integration
Challenge: ESG considerations are often siloed or treated as secondary to financial performance. Leading organizations integrate ESG into strategy, risk management, and Board oversight.
Our Approach:
Board-Level ESG Oversight:
The Board of Directors has ultimate responsibility for ESG matters:
Responsibilities:
Approving ESG Policy and material amendments
Setting ESG strategy, priorities, and targets aligned with business strategy
Reviewing annual ESG reports including performance metrics, risks, and initiatives
Ensuring adequate resources (budget, personnel, expertise) are allocated to ESG initiatives
Holding management accountable for ESG performance
Considering ESG factors in strategic decisions (market expansion, product development, partnerships)
ESG Reporting to Board:
Annual ESG Report: Comprehensive report covering environmental impact (carbon footprint, paperless operations), social impact (financial inclusion metrics, DEI statistics, labor practices), and governance (compliance, AI ethics, Board composition)
Risk Assessment: Identification of material ESG risks (climate-related financial risks, social risks from exclusion or bias, governance risks from weak controls)
Stakeholder Feedback: Summary of stakeholder perspectives on ESG performance (clients, employees, regulators, communities)
Management Accountability:
CEO and COO: Ultimate accountability for ESG strategy execution
ESG Working Group: Cross-functional team (Compliance, Operations, Technology, HR, Risk) coordinating ESG initiatives
ESG Metrics in Performance Reviews: Incorporation of ESG objectives into senior management performance evaluations
Stakeholder Engagement:
Regular engagement with clients, employees, investors, regulators, and civil society on ESG priorities and performance
Transparency through public disclosure of ESG policies and progress (this policy statement, modern slavery statement, diversity data)
Responsiveness to feedback and continuous improvement of ESG approach
3.5 Ethical Business Conduct and Integrity
Challenge: Short-term profit pressures can incentivize corner-cutting, aggressive sales tactics, or ethical compromises.
Our Commitment:
Code of Conduct and Ethics:
Comprehensive Code of Conduct setting clear expectations for ethical behavior - www.unicorncurrencies.com/code-of-conduct
Mandatory annual acknowledgment and training for all employees
Disciplinary consequences for violations, regardless of seniority or revenue impact
Treating Customers Fairly (TCF):
Alignment with FCA Consumer Duty principles ensuring clients achieve good outcomes
Transparent pricing with no hidden spreads or fees
Clear communication in plain language, no jargon or obfuscation
Product suitability assessments ensuring clients understand risks
Support for vulnerable customers facing financial distress or capability issues - www.unicorncurrencies.com/vulnerable-customer-policy
Conflicts of Interest Management:
Identification and disclosure of conflicts of interest
Policies prioritizing client interests over Unicorn's commercial interests
Independence of Compliance and Risk functions from sales and revenue pressures
Regulatory Engagement:
Proactive, transparent engagement with regulators (FINTRAC, FCA)
Commitment to exceeding minimum regulatory requirements where feasible
Participation in regulatory consultations and industry initiatives improving standards
3.6 Corporate Governance Structure
Board Composition:
Diverse Board composition bringing varied expertise (finance, technology, compliance, legal, international business)
Independent directors providing objective oversight (roadmap: addition of independent directors as company matures)
Gender and ethnic diversity targets for Board composition
Governance Committees:
Audit Committee: Overseeing financial reporting, internal controls, and external audit
Risk Committee: Overseeing enterprise risk management including ESG risks
Compliance Committee: Overseeing regulatory compliance and financial crime prevention
Transparency and Accountability:
Regular communication to stakeholders on company performance, strategy, and risks
Public disclosure of material policies (website publication of policies)
Responsiveness to stakeholder questions and concerns
MEASURING OUR IMPACT: ESG Metrics and Targets
Environmental Metrics
Current State (2025):
Paperless Operations: 100% digital KYC and client onboarding; 100% electronic signatures
Cloud Infrastructure: 100% cloud-based infrastructure (AWS, Supabase)
Remote Work: 90%+ of workforce operating remotely full-time
Physical Office Footprint: Minimal (serviced offices and co-working spaces only)
Targets (2026-2030):
Carbon Footprint Measurement: Complete Scope 1, 2, and 3 carbon footprint assessment by end of 2026
Carbon Neutrality: Achieve carbon neutrality by 2030 through emissions reductions and verified carbon offset programs
Renewable Energy: Ensure 100% of cloud infrastructure operates on renewable energy by 2027 (dependent on cloud provider progress)
Sustainable Procurement: 50% of vendors (by spend) to have published environmental policies or certifications by 2028
Social Metrics
Current State (2025):
Financial Inclusion: Serving 887+ active SME clients, many underserved by traditional banks
Transaction Volume: £70M+ processed annually for SME clients
Geographic Diversity: Team across 4 continents
Leadership Diversity: Minority-led organization (Founder & CEO, Co-Founder & COO)
Targets (2026-2030):
Client Growth: Serve 5,000+ SME clients by 2030, with 70%+ qualifying as "underserved" (annual turnover <£10M, first-time FX users, or located in emerging markets)
Gender Diversity: Achieve 40%+ female representation in workforce by 2028; 30%+ at senior management level by 2030
Pay Equity: Conduct annual pay equity audits; eliminate gender/ethnicity pay gaps by 2027
Employee Satisfaction: Achieve 80%+ employee satisfaction score in annual engagement surveys
Modern Slavery Due Diligence: 100% of Tier 1 and Tier 2 suppliers assessed for modern slavery risks by 2026
Financial Literacy: Launch client education program reaching 1,000+ SMEs annually with webinars, guides, and resources by 2027
Governance Metrics
Current State (2025):
Regulatory Compliance: Zero material regulatory breaches or enforcement actions
Data Breaches: Zero data breaches compromising client information
Whistleblower Reports: Confidential reporting channels established; zero reports of retaliation
Training Completion: 100% of employees complete mandatory AML, ABC, and Code of Conduct training annually
Targets (2026-2030):
AI Ethics Framework: Publish comprehensive AI Ethics Statement by 2026; conduct annual AI bias audits commencing 2027
Board Independence: Add 2 independent directors to Board by 2028
Certifications: Achieve SOC 2 Type II (2026) and ISO 27001 (2027) certifications
ESG Reporting: Publish annual ESG Report aligned with GRI standards commencing 2027
Stakeholder Engagement: Conduct annual stakeholder ESG surveys and publish results
Zero Incidents: Maintain zero tolerance record (zero bribery, zero modern slavery, zero material data breaches)
Transparency and Reporting
Annual ESG Reporting
Commencing in 2027, Unicorn Currencies will publish an Annual ESG Report covering:
Environmental Performance: Carbon footprint, energy consumption, paper reduction metrics, remote work statistics
Social Performance: Financial inclusion metrics (clients served, transaction volumes, demographics), workforce diversity statistics, DEI initiatives, employee satisfaction, community engagement, supply chain labor practices
Governance Performance: Compliance metrics (training completion, audit results, regulatory standing), Board composition, ESG governance structures, AI ethics initiatives, incident reports (breaches, violations, whistleblower reports)
Progress Against Targets: Year-over-year progress on ESG targets and commitments
Stakeholder Engagement: Summary of stakeholder feedback and our response
Future Commitments: Updated ESG strategy and targets for upcoming years
External Assurance
As we mature, we will pursue independent third-party assurance of ESG reporting to enhance credibility and accountability, ensuring our disclosures are accurate, complete, and comparable to industry peers.
Stakeholder Feedback
We welcome feedback from clients, employees, partners, regulators, and other stakeholders on our ESG performance and priorities. Please contact:
Email: esg@unicorncurrencies.com
Continuous Improvement
ESG is not a static checklist—it's an ongoing commitment to improvement and responsiveness to evolving expectations.
Our Continuous Improvement Approach:
Annual Policy Review: Reviewing and updating this ESG Policy annually based on performance, stakeholder feedback, and emerging best practices
Benchmarking: Comparing our ESG performance against peer fintech firms and industry standards
Innovation: Exploring new technologies, partnerships, and business models that enhance ESG impact
Transparency: Openly acknowledging shortcomings and sharing lessons learned
Stakeholder Dialogue: Engaging in ongoing dialogue with stakeholders to understand their ESG priorities and concerns
Conclusion
At Unicorn Currencies, ESG is not a compliance exercise or marketing narrative—it's integral to our identity, strategy, and operations.
Environmental: We leverage digital-first operations, carbon-efficient cloud infrastructure, and remote work to minimize our environmental footprint.
Social: We democratize access to institutional-grade treasury services, build a diverse and inclusive organization, and uphold the highest labor and human rights standards.
Governance: We implement robust governance structures, leverage ethical AI, maintain zero tolerance for corruption, and ensure Board-level oversight of ESG risks.
Together, these pillars create a sustainable, inclusive, and trustworthy fintech platform that serves our clients, employees, communities, and the planet responsibly.
We invite you to join us on this journey toward a more sustainable, equitable, and ethical financial services industry.
Related Policies and Resources
Anti-Bribery and Corruption Policy: www.unicorncurrencies.com/abc-policy
Modern Slavery Statement: www.unicorncurrencies.com/modern-slavery-statement
Code of Conduct & Ethics: www.unicorncurrencies.com/code-of-conduct
Whistleblower Policy: www.unicorncurrencies.com/whistleblower-policy
Treating Customers Fairly (TCF): www.unicorncurrencies.com/treating-customers-fairly
Vulnerable Customer Policy: www.unicorncurrencies.com/vulnerable-customer-policy
Privacy Policy: www.unicorncurrencies.com/privacy
Financial Crime Prevention Framework: www.unicorncurrencies.com/financial-crime-prevention
Contact Information
ESG Inquiries:
Email: esg@unicorncurrencies.com
General Inquiries:
UK Phone: +44 (20) 8064-0818
Canada Phone: +1 (548) 488-0818
Email: support@unicorncurrencies.com
Policy Approval
This Environmental, Social, and Governance (ESG) Policy has been approved by the Board of Directors of Unicorn Currencies Limited (Canada) and Unicorn Currencies Ltd (United Kingdom).
Approved by:
Signed:
Nazia M Thakur
Founder & CEO
Unicorn Currencies
Date: December 1, 2025
Next Review Date: December 2026
© 2025 Unicorn Currencies. All rights reserved.
Building a sustainable, inclusive, and ethical future for global treasury management.