Modern Slavery and Human Trafficking Statement

1. INTRODUCTION

1.1 Statement Overview

This Modern Slavery and Human Trafficking Statement (the "Statement") is made by Unicorn Currencies Limited (Canada) and Unicorn Currencies Ltd (United Kingdom) (collectively "Unicorn", "we", "us", or "our") for the financial year ending December 31, 2025.

This Statement is published voluntarily in accordance with the spirit and principles of the UK Modern Slavery Act 2015, Section 54, which requires certain commercial organizations to publish annual statements describing the steps they have taken to ensure that slavery and human trafficking are not taking place in their business operations or supply chains.

Although Unicorn Currencies Ltd (UK) does not currently meet the revenue threshold requiring mandatory compliance with Section 54 of the Modern Slavery Act 2015, we believe that transparency and accountability regarding modern slavery risks are fundamental to ethical business conduct and corporate social responsibility.

1.2 Our Commitment

Unicorn Currencies is unequivocally opposed to modern slavery and human trafficking in all forms.

We are committed to:

(a) Conducting our business operations with integrity, respect for human rights, and in compliance with all applicable laws;

(b) Ensuring that slavery, servitude, forced or compulsory labor, and human trafficking (collectively "modern slavery") do not exist within our business or supply chains;

(c) Implementing robust due diligence processes to identify, assess, and mitigate modern slavery risks;

(d) Partnering only with suppliers, vendors, and business partners who share our commitment to ethical conduct and human rights;

(e) Providing transparency regarding our policies, processes, and progress in combating modern slavery;

(f) Continuously improving our practices through risk assessment, training, and stakeholder engagement.

2. ORGANIZATIONAL STRUCTURE AND BUSINESS

2.1 About Unicorn Currencies

Unicorn Currencies operates as a dual-entity organization providing foreign exchange and payment services to business clients:

2.1.1 Unicorn Currencies Limited (Canada)

Jurisdiction: British Columbia, Canada

Incorporation Number: BC1473865

Registered Address: 5577 153A Street, Suite 207, Surrey, V3S 5K7, British Columbia, Canada

Regulatory Status: Registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a Money Service Business (MSB) and Payment Service Provider (PSP) under registration number C100000159

Geographic Scope: Serves clients in Canada and the United States

2.1.2 Unicorn Currencies Ltd (United Kingdom)

Jurisdiction: England & Wales

Company Registration Number: 14325478

Registered Address: 4th Floor, Silverstream House, Fitzroy Street, London, W1T 6EB, United Kingdom

Regulatory Status: Registered with the UK Information Commissioner's Office (ICO Registration No: ZB534346); operates as a Program Manager in partnership with FCA-authorized Payment Service Providers

Geographic Scope: Serves clients in the United Kingdom, European Union, and Rest of World territories

2.2 Our Business Model

Unicorn Currencies provides:

(a) Foreign Exchange Services: Currency conversion and hedging products for businesses engaged in international trade;

(b) International Payment Services: Cross-border payment execution via SWIFT, SEPA, and other payment networks;

(c) Treasury Management Services: Multi-currency accounts, payment automation, and reporting tools.

Our clients include import/export firms, e-commerce businesses, professional services firms, and other commercial entities requiring foreign exchange and international payment solutions.

2.3 Workforce

As of December 31, 2025, Unicorn Currencies employs approximately:

(a) 15 permanent employees across Canada and the United Kingdom in roles including compliance, operations, sales, customer service, and management;

(b) 5 contractors and consultants providing specialized services including technology development, legal advisory, and business development.

All employees and contractors are:

• Hired through formal recruitment processes with employment contracts or service agreements;

• Subject to background checks and right-to-work verification;

• Paid fair wages in compliance with applicable minimum wage laws and employment standards;

• Provided with working conditions that meet or exceed legal requirements;

• Protected by employment laws prohibiting forced labor, child labor, and exploitation.

We do NOT employ workers in high-risk jurisdictions or sectors known for modern slavery vulnerabilities (such as agriculture, construction, manufacturing, hospitality, or domestic work).

3. SUPPLY CHAINS AND MODERN SLAVERY RISK ASSESSMENT

3.1 Overview of Our Supply Chains

Unlike manufacturing, retail, or agriculture businesses with complex global supply chains, Unicorn Currencies operates primarily in the financial services sector with relatively simple, technology-focused supply chains.

Our key suppliers and business partners include:

3.1.1 Technology Vendors and Software Providers

(a) Cloud Hosting and Infrastructure: Amazon Web Services (AWS), Microsoft Azure, Google Cloud Platform;

(b) Software-as-a-Service (SaaS) Platforms: Salesforce (CRM), Zoho (business operations), HubSpot (marketing automation), Intercom (customer support);

(c) Identity Verification and Compliance Vendors: Onfido, Jumio, Trulioo, GB Group, Dow Jones Risk & Compliance, ComplyAdvantage;

(d) Payment Processing Infrastructure: Stripe, Plaid, banking APIs;

(e) Web Development and Hosting: Framer, web design agencies, freelance developers;

(f) Cybersecurity and Monitoring: Cloudflare, Sentry, security consulting firms.

3.1.2 Banking Partners and Payment Service Providers

(a) Canadian Chartered Banks: Tier-1 banks providing segregated trust accounts for client fund safeguarding;

(b) FCA-Authorized Payment Service Providers: UK and EU partners including Equals Money, Clear Currency, and similar institutions facilitating payment execution and safeguarding;

(c) Correspondent Banks: SWIFT member banks facilitating international payment routing.

3.1.3 Professional Services

(a) Legal Advisors: Law firms providing regulatory, compliance, and corporate legal services;

(b) Accounting and Audit Firms: External auditors and accountants;

(c) Consulting Services: Compliance consultants, business advisors, marketing agencies.

3.1.4 Office and Operational Suppliers

(a) Office Equipment and Supplies: Computers, telecommunications equipment, office furniture, stationery;

(b) Facilities Management: Office lease providers, cleaning services, utilities;

(c) Corporate Services: Business insurance brokers, registered office providers.

3.2 Modern Slavery Risk Assessment

We have conducted a risk assessment of our supply chains to identify potential modern slavery vulnerabilities:

3.2.1 Low-Risk Supply Chain Categories

Technology Vendors and SaaS Providers:

• Risk Level: LOW

• Rationale: Large, publicly traded or well-established technology companies (AWS, Microsoft, Google, Salesforce, Stripe) with:

  • Strong corporate governance and ethics programs;

  • Published modern slavery statements and human rights policies;

  • High-skilled, well-compensated workforces in developed countries;

  • Transparent operations subject to regulatory and investor scrutiny;

  • Established supply chain due diligence practices.

Banking Partners:

• Risk Level: LOW

• Rationale: Tier-1 banks and FCA-authorized financial institutions with:

  • Stringent regulatory oversight and compliance obligations;

  • Mandatory modern slavery statement requirements (under UK Modern Slavery Act);

  • Robust internal controls and ethical standards;

  • High-skilled professional workforces;

  • Transparent corporate structures and operations.

Professional Services (Legal, Accounting, Consulting):

• Risk Level: LOW

• Rationale: Professional services firms with:

  • Highly educated, professionally qualified workforces;

  • Ethical codes and professional conduct standards;

  • Transparent fee structures and client relationships;

  • Regulatory oversight (for law firms and accounting firms);

  • Established reputation and brand protection incentives.

3.2.2 Medium-Risk Supply Chain Categories

Web Development and Design Agencies / Freelancers:

• Risk Level: MEDIUM

• Rationale: Smaller agencies or individual contractors may:

  • Subcontract work to developers in jurisdictions with weaker labor protections;

  • Lack formal modern slavery due diligence processes;

  • Have less transparent supply chains.

• Mitigation: See Section 4.3.

Office Equipment and Electronics Suppliers:

• Risk Level: MEDIUM

• Rationale: Electronics manufacturing supply chains (computers, mobile devices, servers) have documented modern slavery risks including:

  • Forced labor in mining of conflict minerals (cobalt, tantalum, tin, tungsten);

  • Exploitative labor practices in electronics manufacturing (particularly in Asia);

  • Use of temporary or agency workers in vulnerable conditions.

• Mitigation: See Section 4.4.

Cleaning and Facilities Services:

• Risk Level: MEDIUM (if outsourced)

• Rationale: Cleaning and facilities management sectors have documented modern slavery vulnerabilities including:

  • Use of migrant workers with precarious immigration status;

  • Subcontracting and labor agency practices obscuring employment relationships;

  • Low-wage, low-skilled work vulnerable to exploitation.

• Current Status: Minimal risk as Unicorn operates primarily in serviced office spaces where facilities management is provided by landlords. Where we engage cleaning or facilities services directly, we conduct due diligence (see Section 4.5).

3.2.3 Risk Factors Considered

Our risk assessment considers:

(a) Geographic Risk: Suppliers operating in or sourcing from countries with high prevalence of modern slavery (as identified by the Global Slavery Index);

(b) Sectoral Risk: Industries known for modern slavery vulnerabilities (manufacturing, agriculture, construction, hospitality, domestic work, electronics);

(c) Business Model Risk: Use of subcontracting, labor agencies, or complex supply chains that obscure employment relationships;

(d) Workforce Characteristics: Reliance on migrant workers, low-skilled workers, temporary workers, or workers with precarious legal status;

(e) Supplier Size and Transparency: Smaller suppliers with less robust governance, compliance, and transparency.

3.3 Overall Risk Profile

Our overall modern slavery risk profile is LOW to MEDIUM, primarily due to:

(a) Financial services sector focus: We do not operate in high-risk sectors such as manufacturing, agriculture, or construction;

(b) Technology-driven supply chains: Our key suppliers are large, reputable technology and financial services firms with strong ethical standards;

(c) Developed country operations: Our direct operations and most suppliers are in Canada, UK, and other developed countries with strong labor protections;

(d) High-skilled workforce: Both our employees and our suppliers' employees are predominantly high-skilled professionals with strong bargaining power and legal protections;

(e) Limited indirect supply chain exposure: We have minimal exposure to extended supply chains in high-risk jurisdictions.

However, we recognize that modern slavery risks can exist in unexpected areas (such as electronics supply chains or subcontracted services) and remain vigilant.

4. DUE DILIGENCE PROCESSES

4.1 Supplier Onboarding and Vetting

Unicorn Currencies implements the following due diligence processes for all new suppliers and business partners:

4.1.1 Standard Supplier Due Diligence

For all suppliers, we conduct:

(a) Identity and Legal Verification: Confirmation of legal entity name, registration number, registered address, and corporate structure;

(b) Reputation and References: Review of publicly available information, client references, and business track record;

(c) Financial Stability Assessment: Evaluation of financial viability to ensure legitimate, sustainable operations;

(d) Sanctions and Adverse Media Screening: Screening against sanctions lists and adverse media databases to identify unethical or illegal conduct;

(e) Modern Slavery Questionnaire: For medium and high-value suppliers (annual spend over £10,000 / CAD $15,000), we require completion of a supplier questionnaire covering:

• Existence of modern slavery policies;

• Due diligence on their own supply chains;

• Training programs for employees;

• Any past allegations or incidents related to labor rights violations;

• Subcontracting practices and transparency.

4.1.2 Enhanced Due Diligence for High-Risk Suppliers

For suppliers identified as higher-risk (based on sector, geography, or business model), we conduct enhanced due diligence including:

(a) Site visits or video audits (where feasible and proportionate);

(b) Request for copies of supplier policies including modern slavery policies, codes of conduct, and human rights policies;

(c) Review of supplier's own modern slavery statement (if applicable);

(d) Third-party audit reports or certifications (e.g., ISO standards, industry certifications, social compliance audits);

(e) Assessment of subcontracting practices and transparency regarding lower-tier suppliers.

4.2 Contractual Protections

All supplier contracts include:

(a) Modern Slavery Compliance Clause requiring the supplier to:

• Comply with all applicable modern slavery laws including the UK Modern Slavery Act 2015 and Canada's prohibitions on forced labor;

• Ensure that slavery and human trafficking do not exist in their business or supply chains;

• Conduct due diligence on their own suppliers;

• Provide evidence of compliance upon request;

(b) Representations and Warranties that the supplier is not aware of and has not been involved in any modern slavery violations;

(c) Right to Audit allowing Unicorn to audit the supplier's compliance with modern slavery obligations;

(d) Whistleblowing and Reporting Requirements obligating the supplier to promptly report any suspicions or allegations of modern slavery;

(e) Termination Rights allowing Unicorn to immediately terminate the contract if the supplier violates modern slavery laws or obligations;

(f) Indemnification holding the supplier liable for any losses, damages, or penalties arising from their modern slavery violations.

4.3 Due Diligence on Technology Vendors

For our key technology vendors (cloud hosting, SaaS platforms, identity verification providers):

(a) Review of published modern slavery statements (required for UK companies with turnover over £36 million and standard practice for large US corporations);

(b) Review of corporate social responsibility (CSR) reports and human rights policies;

(c) Assessment of vendor's supply chain transparency and due diligence practices;

(d) Preference for vendors with strong ethical commitments and published supplier codes of conduct.

Examples:

• Amazon Web Services (AWS): Published modern slavery statement, comprehensive CSR programs, supplier code of conduct;

• Microsoft: Annual human rights report, modern slavery statement, ethical AI principles;

• Google: Supplier code of conduct, responsible supply chain programs, transparency reports;

• Salesforce: Published modern slavery statement, ethical and humane use policy, stakeholder impact reports.

4.4 Due Diligence on Office Equipment and Electronics Suppliers

Recognizing the modern slavery risks in electronics supply chains, we:

(a) Prioritize suppliers with conflict minerals policies and due diligence on mineral sourcing;

(b) Request information on manufacturing practices and labor conditions in factories;

(c) Favor suppliers with certifications such as:

• Responsible Business Alliance (RBA) membership;

• ISO 26000 (Social Responsibility);

• SA8000 (Social Accountability International standard);

• Fair Trade or other ethical sourcing certifications;

(d) Purchase from reputable brands with established corporate responsibility programs (e.g., Apple, Dell, HP, Lenovo) that publish modern slavery statements and supply chain transparency reports;

(e) Extend equipment lifecycles and implement recycling programs to reduce demand for newly manufactured electronics.

4.5 Due Diligence on Cleaning and Facilities Services

Where we directly engage cleaning or facilities services providers, we:

(a) Verify that all workers are directly employed (not agency workers with precarious status);

(b) Confirm compliance with National Minimum Wage / Living Wage requirements;

(c) Verify right to work documentation for all workers providing services at our premises;

(d) Conduct on-site observations to assess working conditions and worker wellbeing;

(e) Provide accessible reporting mechanisms for workers to raise concerns confidentially;

(f) Favor suppliers with Investors in People or similar accreditations demonstrating commitment to ethical employment practices.

4.6 Banking Partner Due Diligence

Our banking partners (Canadian chartered banks, FCA-authorized payment service providers) are subject to:

(a) Regulatory due diligence as part of our account opening and partnership onboarding;

(b) Review of published modern slavery statements (mandatory for UK banks and financial institutions over the threshold);

(c) Assessment of corporate governance and ethics programs;

(d) Ongoing monitoring through relationship management and regulatory compliance reviews.

Given the highly regulated nature of the banking sector and mandatory modern slavery compliance for large financial institutions, our banking partners present minimal modern slavery risk.

5. POLICIES AND GOVERNANCE

5.1 Internal Policies

Unicorn Currencies has implemented the following policies supporting our commitment to combating modern slavery:

5.1.1 Code of Conduct and Ethics

Our Code of Conduct requires all employees, officers, and directors to:

(a) Respect human rights and dignity in all business dealings;

(b) Comply with all applicable employment and labor laws;

(c) Avoid complicity in human rights abuses including forced labor and human trafficking;

(d) Report any suspicions or evidence of modern slavery.

5.1.2 Anti-Bribery and Corruption (ABC) Policy

Our ABC Policy (in accordance with UK Bribery Act 2010 and Canadian CFPOA) prohibits:

(a) Any form of bribery or corruption in our business operations or supply chains;

(b) Facilitation payments that could enable or conceal modern slavery;

(c) Engagement with business partners involved in unethical or illegal conduct.

Relevance to Modern Slavery: Bribery and corruption often facilitate modern slavery by enabling officials to overlook labor violations or by allowing unscrupulous businesses to operate with impunity.

5.1.3 Whistleblower Policy

Our Whistleblower Policy provides:

(a) Confidential reporting channels for employees and third parties to report suspected modern slavery or other serious concerns;

(b) Non-retaliation protections ensuring individuals can report concerns without fear of retaliation;

(c) Investigation procedures for all reports received;

(d) Escalation to law enforcement where criminal conduct (including modern slavery) is identified.

Reporting Channels:

• Email: compliance@unicorncurrencies.com

• Phone: +44 (20) 8064-0818 (UK) | +1 (548) 488-0818 (Canada)

• Anonymous reporting is permitted where feasible

5.1.4 Recruitment and Employment Practices

Our recruitment and HR practices ensure:

(a) Transparent, fair recruitment processes with formal employment contracts;

(b) Right to work verification for all employees in accordance with UK and Canadian immigration laws;

(c) Payment of fair wages meeting or exceeding National Minimum Wage / Living Wage requirements;

(d) No fees charged to workers for recruitment, employment, or immigration processing (we cover all costs);

(e) No retention of identity documents or passports (employees retain control of their documents);

(f) Freedom of movement with no restrictions on workers' ability to leave employment;

(g) Written employment contracts in the worker's native language explaining terms, conditions, and rights;

(h) Compliance with working time regulations including rest breaks, paid leave, and maximum working hours;

(i) Prohibition on child labor (all employees must be 18 or over);

(j) Equal opportunity employment free from discrimination and harassment.

5.1.5 Third-Party Management Policy

Our Third-Party Management Policy requires:

(a) Due diligence on all third parties (see Section 4);

(b) Contractual modern slavery compliance clauses;

(c) Ongoing monitoring and periodic re-assessment of third-party relationships;

(d) Termination of relationships with third parties engaged in modern slavery or unethical conduct.

5.2 Governance and Oversight

5.2.1 Board of Directors

The Board of Directors:

(a) Approves this Modern Slavery Statement annually;

(b) Oversees the Company's modern slavery compliance program;

(c) Receives annual reports on modern slavery risks, due diligence activities, and incidents (if any);

(d) Sets the ethical tone and expectations for the organization.

5.2.2 Chief Operating Officer (COO)

The COO is responsible for:

(a) Implementing and enforcing modern slavery policies and due diligence processes;

(b) Ensuring adequate resources are allocated to modern slavery compliance;

(c) Reviewing and approving supplier relationships;

(d) Reporting to the Board on modern slavery matters.

5.2.3 Compliance Officer

The Compliance Officer is responsible for:

(a) Day-to-day administration of the modern slavery compliance program;

(b) Conducting supplier due diligence and risk assessments;

(c) Maintaining records of due diligence activities;

(d) Providing training and guidance to employees;

(e) Investigating reports of suspected modern slavery;

(f) Coordinating with law enforcement and regulatory authorities as needed.

5.2.4 All Employees

All employees are responsible for:

(a) Understanding Unicorn's commitment to combating modern slavery;

(b) Reporting any suspicions or concerns regarding modern slavery;

(c) Cooperating with due diligence and audit processes;

(d) Upholding ethical standards in all business dealings.

6. TRAINING AND AWARENESS

6.1 Employee Training

Unicorn Currencies provides training to ensure employees understand modern slavery risks and their role in combating exploitation:

6.1.1 Induction Training

All new employees receive induction training covering:

(a) Overview of modern slavery (definitions, forms, prevalence);

(b) UK Modern Slavery Act 2015 and Canadian legal framework;

(c) Unicorn's commitment and policies;

(d) Red flags and indicators of modern slavery;

(e) Reporting obligations and whistleblower protections.

6.1.2 Role-Specific Training

Employees in roles with higher exposure to modern slavery risks receive enhanced training:

(a) Procurement and Operations Teams: Training on supplier due diligence, contract management, and modern slavery risk assessment;

(b) Compliance and Legal Teams: Advanced training on regulatory requirements, investigation procedures, and remediation;

(c) HR and Recruitment: Training on ethical recruitment practices and identifying exploitation in employment relationships;

(d) Senior Management: Training on governance, risk oversight, and strategic responses to modern slavery.

6.1.3 Refresher Training

All employees receive annual refresher training on modern slavery to:

(a) Reinforce knowledge and awareness;

(b) Update on changes in law, policy, or best practices;

(c) Share lessons learned and case studies;

(d) Reaffirm Unicorn's commitment and expectations.

6.2 Training Content and Resources

Training materials include:

(a) Definitions and Context: Explanation of modern slavery, human trafficking, forced labor, servitude, and related concepts;

(b) Legal Framework: Overview of UK Modern Slavery Act 2015, Criminal Code of Canada, and international instruments (ILO conventions, UN Guiding Principles on Business and Human Rights);

(c) Sector-Specific Risks: Discussion of modern slavery risks in technology, financial services, and support functions;

(d) Red Flags and Indicators: How to identify potential modern slavery including:

• Workers who appear malnourished, injured, or in poor health;

• Workers lacking freedom of movement or living in substandard accommodation;

• Workers without proper documentation or whose documents are held by employers;

• Evidence of debt bondage or fees charged for employment;

• Workers fearful of authorities or reluctant to speak freely;

• Inconsistent or scripted answers to questions about working conditions;

• Evidence of excessive working hours with little or no time off;

• Payment irregularities (wages below minimum wage, unexplained deductions, payment in kind);

(e) Reporting Procedures: Clear guidance on how and where to report concerns;

(f) Case Studies: Real-world examples and scenarios to illustrate modern slavery risks and appropriate responses;

(g) Resources and Support: Contact information for internal reporting channels and external support organizations.

6.3 Supplier Awareness

We communicate our expectations to suppliers through:

(a) Supplier Code of Conduct: Distributed to all suppliers, setting out ethical and legal expectations including prohibition on modern slavery;

(b) Contractual Clauses: Modern slavery compliance provisions in all supplier contracts (see Section 4.2);

(c) Supplier Communications: Periodic reminders and updates on our modern slavery expectations and best practices;

(d) Supplier Training (for high-risk or strategic suppliers): Offers of training resources or joint workshops on modern slavery risks and due diligence.

7. MEASURING EFFECTIVENESS

7.1 Key Performance Indicators (KPIs)

Unicorn Currencies measures the effectiveness of our modern slavery program using the following KPIs:

7.1.1 Supplier Due Diligence

(a) Percentage of new suppliers subject to modern slavery due diligence: Target 100%;

(b) Percentage of high-risk suppliers with enhanced due diligence completed: Target 100%;

(c) Percentage of supplier contracts containing modern slavery clauses: Target 100% (for new contracts and contract renewals).

7.1.2 Training and Awareness

(a) Percentage of employees completing modern slavery training: Target 100% within 30 days of hire and annually thereafter;

(b) Training completion rate by department and role: Monitored to ensure comprehensive coverage;

(c) Employee knowledge assessments: Periodic quizzes or surveys to test understanding.

7.1.3 Reporting and Incidents

(a) Number of modern slavery concerns reported: Tracked through whistleblower channels;

(b) Response time for investigating reports: Target investigation initiation within 48 hours;

(c) Number of substantiated incidents: Zero tolerance with immediate remediation;

(d) Supplier terminations for modern slavery violations: Tracked and analyzed.

7.1.4 Supply Chain Transparency

(a) Percentage of tier-1 suppliers assessed for modern slavery risk: Target 100%;

(b) Percentage of high-risk suppliers with published modern slavery statements or CSR reports: Tracked to assess supplier transparency;

(c) Supply chain mapping progress: Ongoing effort to understand tier-2 and tier-3 suppliers where relevant.

7.2 Annual Review and Reporting

The Compliance Officer conducts an annual review of the modern slavery program, including:

(a) Analysis of KPIs and progress against targets;

(b) Risk assessment to identify emerging modern slavery risks in supply chains or operations;

(c) Policy and process improvements based on lessons learned, regulatory changes, and best practices;

(d) Incident review (if any incidents occurred) to understand root causes and implement corrective actions;

(e) Recommendations for enhanced due diligence, training, or resource allocation.

The annual review is reported to the COO and Board of Directors and informs the publication of the following year's Modern Slavery Statement.

7.3 Continuous Improvement

We are committed to continuously improving our modern slavery program through:

(a) Benchmarking against industry best practices and guidance from organizations such as:

• UK Home Office statutory guidance on modern slavery statements;

• Ethical Trading Initiative (ETI) base code;

• UN Guiding Principles Reporting Framework;

• OECD Due Diligence Guidance for Responsible Business Conduct;

(b) Stakeholder engagement including dialogue with suppliers, industry peers, civil society organizations, and experts on modern slavery;

(c) Technology adoption including use of supply chain mapping tools, AI-powered risk screening, and blockchain-based supply chain transparency (where applicable);

(d) Collaboration with industry initiatives, working groups, and multi-stakeholder forums addressing modern slavery in financial services and technology sectors.

8. INCIDENTS AND REMEDIATION

8.1 Reporting Period: FY 2025

For the financial year ending December 31, 2025:

(a) Zero incidents of modern slavery or human trafficking were identified within Unicorn Currencies' direct operations;

(b) Zero reports of modern slavery concerns related to our suppliers or business partners were received through whistleblower channels;

(c) No supplier relationships were terminated due to modern slavery violations.

8.2 Remediation Framework

In the event that modern slavery is identified within our operations or supply chains, we commit to the following remediation approach:

8.2.1 Immediate Actions

(a) Cease harmful activity: Immediately stop any business practices contributing to the exploitation;

(b) Victim protection: Prioritize the safety, wellbeing, and agency of victims;

(c) Engagement with authorities: Report to law enforcement (UK National Referral Mechanism, Canadian authorities) and cooperate with investigations;

(d) Suspension of supplier relationships: Suspend or terminate relationships with suppliers engaged in modern slavery pending investigation and remediation.

8.2.2 Investigation and Root Cause Analysis

(a) Conduct thorough investigation to understand how the modern slavery occurred;

(b) Identify failures in due diligence, controls, or oversight;

(c) Assess accountability (individuals, suppliers, processes responsible);

(d) Determine appropriate remedial measures.

8.2.3 Victim Support and Remediation

(a) Access to remedy: Provide or facilitate access to effective remedy for victims including:

• Compensation for unpaid wages, exploitation, or harm suffered;

• Support for safe return home or regularization of immigration status;

• Access to medical, psychological, and legal support services;

• Cooperation with victim support organizations and referral mechanisms;

(b) Non-retaliation: Ensure victims are not penalized or punished for their situation;

(c) Long-term support: Consider ongoing support to prevent re-victimization.

8.2.4 Corrective Actions and Prevention

(a) Strengthen due diligence: Enhance screening, monitoring, and audit processes;

(b) Supplier engagement: Work with suppliers to improve their practices and prevent recurrence (or terminate relationship if improvement is not possible);

(c) Policy and process improvements: Update policies, procedures, and training based on lessons learned;

(d) Increased monitoring: Implement enhanced oversight of high-risk areas identified through the incident;

(e) Transparency: Publicly disclose incidents and remediation efforts in the following year's Modern Slavery Statement (balancing transparency with victim privacy and legal considerations).

8.2.5 Accountability

(a) Internal accountability: Disciplinary action against employees who failed to exercise appropriate due diligence or who were complicit in modern slavery;

(b) Supplier accountability: Legal action, termination, and/or referral to authorities for suppliers engaged in modern slavery;

(c) Reporting to Board: Board oversight of incidents and remediation efforts.

9. COLLABORATION AND ENGAGEMENT

9.1 Industry Collaboration

Unicorn Currencies recognizes that combating modern slavery requires collective action. We engage with:

(a) Industry associations and working groups addressing modern slavery in financial services and fintech sectors;

(b) Peer companies to share best practices, due diligence approaches, and lessons learned;

(c) Multi-stakeholder initiatives such as:

• Finance Against Slavery and Trafficking (FAST);

• Liechtenstein Initiative for Finance Against Slavery and Trafficking;

• Responsible Business Alliance (RBA) for technology supply chain issues.

9.2 Civil Society and Expert Engagement

We seek guidance and input from:

(a) Anti-slavery organizations such as:

• Anti-Slavery International;

• Walk Free Foundation;

• Hope for Justice;

• Unseen UK;

(b) Human rights organizations providing expertise on due diligence and remedy;

(c) Academic and research institutions advancing understanding of modern slavery risks in financial services and technology sectors;

(d) Legal and compliance consultants specializing in modern slavery law and best practices.

9.3 Government and Regulatory Engagement

We engage constructively with:

(a) UK Home Office and regulatory bodies on modern slavery policy and compliance;

(b) Global Affairs Canada and RCMP on forced labor and human trafficking issues;

(c) Consultations and policy submissions contributing to the development of effective modern slavery regulation;

(d) Law enforcement cooperation if modern slavery is identified in our operations or supply chains.

9.4 Supplier Engagement and Capacity Building

We actively engage with our suppliers to:

(a) Communicate expectations regarding modern slavery compliance;

(b) Provide resources and guidance on conducting their own modern slavery due diligence;

(c) Offer support (where feasible) to smaller suppliers seeking to improve their modern slavery practices;

(d) Encourage transparency through publication of modern slavery statements and participation in industry initiatives;

(e) Foster long-term partnerships with ethical suppliers committed to continuous improvement.

10. LOOKING AHEAD: FY 2026 COMMITMENTS

10.1 Strengthening Due Diligence

In FY 2026, we commit to:

(a) Enhanced supply chain mapping: Conducting deeper analysis of tier-2 and tier-3 suppliers (suppliers to our suppliers) in higher-risk categories (electronics, facilities services);

(b) Supplier audits: Conducting on-site or virtual audits of select high-risk suppliers to verify working conditions and modern slavery compliance;

(c) Third-party risk assessments: Engaging specialized due diligence providers for in-depth assessments of suppliers in higher-risk jurisdictions or sectors;

(d) Conflict minerals due diligence: Implementing enhanced due diligence on electronics suppliers to trace sourcing of minerals and ensure conflict-free supply chains.

10.2 Expanding Training and Awareness

In FY 2026, we commit to:

(a) Enhanced training content: Developing more detailed, role-specific training modules with interactive scenarios and case studies;

(b) Supplier training program: Offering training webinars or resources to our suppliers on modern slavery risks and best practices;

(c) Client and partner engagement: Exploring opportunities to raise awareness of modern slavery issues with clients and banking partners, fostering collective action;

(d) Public awareness: Participating in Modern Slavery Awareness Week or similar campaigns to demonstrate public commitment.

10.3 Improving Measurement and Transparency

In FY 2026, we commit to:

(a) Enhanced KPI tracking: Implementing more granular KPIs and dashboards for real-time monitoring of modern slavery compliance;

(b) Supply chain transparency reporting: Publishing more detailed information about our tier-1 suppliers and their modern slavery practices;

(c) Benchmarking: Comparing our modern slavery program against industry best practices and identifying gaps for improvement;

(d) Independent assurance: Exploring options for third-party assurance or certification of our modern slavery program.

10.4 Policy and Governance Enhancements

In FY 2026, we commit to:

(a) Standalone Modern Slavery Policy: Developing a comprehensive standalone Modern Slavery Policy complementing this annual statement and integrated with other corporate policies;

(b) Supplier Code of Conduct: Publishing a detailed Supplier Code of Conduct with explicit modern slavery provisions, ethical sourcing standards, and remediation expectations;

(c) Whistleblower mechanism enhancement: Implementing a dedicated anonymous reporting hotline for modern slavery concerns;

(d) Board oversight: Establishing a formal Board-level review of modern slavery risks and program effectiveness at least twice annually.

10.5 Collaboration and Advocacy

In FY 2026, we commit to:

(a) Industry initiative participation: Joining at least one multi-stakeholder initiative or working group focused on modern slavery in financial services or technology;

(b) Peer learning: Engaging with peer companies to share best practices and lessons learned;

(c) Advocacy: Supporting stronger modern slavery legislation and enforcement in Canada and internationally, advocating for:

• Extension of mandatory modern slavery reporting requirements in Canada (currently voluntary);

• Increased penalties and enforcement for modern slavery violations;

• Greater transparency and due diligence obligations for companies.

11. APPROVAL AND SIGN-OFF

This Modern Slavery and Human Trafficking Statement has been approved by the Board of Directors of Unicorn Currencies Limited (Canada) and Unicorn Currencies Ltd (United Kingdom) and is signed by authorized representatives:

For Unicorn Currencies Limited (Canada):

Signed:

Mohsen M Thakur
Chief Operating Officer and Co-Founder
Unicorn Currencies Limited

Date: December 4, 2025

For Unicorn Currencies Ltd (United Kingdom):

Signed:

Mohsen M Thakur
Chief Operating Officer and Co-Founder
Unicorn Currencies Ltd

Date: December 4, 2025

This Statement is published in accordance with Section 54 of the UK Modern Slavery Act 2015 (voluntary compliance) and constitutes our slavery and human trafficking statement for the financial year ending December 31, 2025.

12. CONTACT INFORMATION

For questions, concerns, or to report suspected modern slavery, please contact:

Compliance Officer / Head of Compliance

Email: compliance@unicorncurrencies.com

UK Phone: +44 (20) 8064-0818

Canada Phone: +1 (548) 488-0818

Address (UK):
Compliance Department
Unicorn Currencies Ltd
4th Floor, Silverstream House, Fitzroy Street
London, W1T 6EB
United Kingdom

Address (Canada):
Compliance Department
Unicorn Currencies Limited
5577 153A Street, Suite 207
Surrey, V3S 5K7, British Columbia
Canada

13. ADDITIONAL RESOURCES

Modern Slavery Reporting and Support:

(a) UK Modern Slavery Helpline: 08000 121 700 | https://www.modernslaveryhelpline.org

(b) UK National Referral Mechanism: For referring potential victims of modern slavery | https://www.gov.uk/government/collections/national-referral-mechanism

(c) Canadian Human Trafficking Hotline: 1-833-900-1010 | https://www.canadianhumantraffickinghotline.ca

(d) Global Modern Slavery Directory: https://www.globalslaveryindex.org

(e) Ethical Trading Initiative (ETI): https://www.ethicaltrade.org

(f) Walk Free Foundation: https://www.walkfree.org

(g) UN Guiding Principles Reporting Framework: https://www.ungpreporting.org

14. RELATED POLICIES

This Modern Slavery Statement should be read in conjunction with:

(a) Code of Conduct and Ethics

(b) Anti-Bribery and Corruption Policy: www.unicorncurrencies.com/anti-bribery-policy

(c) Whistleblower Policy

(d) Third-Party Management Policy

(e) Supplier Code of Conduct (to be published FY 2026)

(f) Master Services Agreement: www.unicorncurrencies.com/terms

(g) Privacy Policy: www.unicorncurrencies.com/privacy

(h) Safeguarding Policy: www.unicorncurrencies.com/safeguarding

(i) Complaint Handling Procedure: www.unicorncurrencies.com/complaints

This Modern Slavery and Human Trafficking Statement is published voluntarily by Unicorn Currencies Limited and Unicorn Currencies Ltd and constitutes our commitment to transparency, ethical business conduct, and respect for human rights.

© 2025 Unicorn Currencies. All rights reserved.