Modern Slavery Statement

Liberis operates through entities across the UK, EU, North America and India, employing staff primarily in professional, technology, and operational roles. Our core activities include embedded finance partnerships, technology development, and SME funding operations.

This statement is published pursuant to section 54 of the UK Modern Slavery Act 2015 and sets out the steps Liberis has taken during the financial year ending 2025 to prevent modern slavery and human trafficking in its business and supply chains.

Liberis has a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically and with integrity in all our business dealings and to implementing effective systems and controls to ensure modern slavery is not taking place in our own business or in any of our supply chains.

This statement applies to all persons working for us or on our behalf in any capacity, including employees, directors, officers, contractors, agents, and business partners.

The Board of Directors has overall responsibility for ensuring this statement complies with Liberis’ legal and ethical obligations. The Director of Compliance has day-to-day oversight of its implementation and effectiveness. Management at all levels are responsible for ensuring those within their areas of responsibility understand and comply with this statement.

Queries and concerns relating to modern slavery should be directed to compliance@liberis.com.

Prior to joining Liberis, all employees are subject to background checks and screening. All employees are required to complete mandatory training covering business compliance, anti-financial crime, information security, and data protection. Relevant employees receive periodic training on identifying and escalating modern slavery risks, proportionate to their role.

Liberis maintains a suite of policies that support the identification and mitigation of modern slavery risks. These include policies covering supplier and partner due diligence, anti-bribery and corruption, whistleblowing, and data protection. Specific prohibitions against forced, compulsory, or trafficked labour are included in our supplier and partner contracts.

Employees and third parties can raise concerns confidentially and without fear of retaliation through our whistleblowing process by contacting compliance@liberis.com.

Our supply chain is not complex. It is primarily comprised of technology and data vendors, professional advisory firms, and office facilities providers. Liberis also works with a network of regulated commercial partners to deliver its embedded finance product; these partners are subject to their own modern slavery obligations, though Liberis conducts its own risk-based due diligence and does not rely solely on regulatory status.

Liberis applies proportionate, risk-based due diligence to suppliers and partners. This may include screening, review of policies and contractual commitments, beneficial ownership checks, and adverse media screening. Where gaps are identified, Liberis may require corrective action, enhanced monitoring, or, where appropriate, termination of the relationship.

Liberis does not operate in sectors typically associated with high inherent modern slavery risk. Risk assessments are conducted using criteria including geography, sector exposure, and supply chain complexity, and are reviewed annually or where there are material changes to operations or supply chain.

Liberis’ India operations are assessed as presenting a low inherent risk. India-based individuals are engaged in professional, skilled roles - principally software engineering, product management, finance and risk functions. These roles carry materially lower exposure to modern slavery risk compared to manual labour, manufacturing, or lower-wage sectors. No supply chain activity is routed through the India operations. Liberis applies its standard screening and onboarding requirements to all individuals working on its behalf regardless of engagement structure. This assessment is reviewed annually.

Where suppliers, partners, or operational activities are linked to higher-risk jurisdictions or sectors, Liberis applies enhanced due diligence and increased monitoring proportionate to the risk identified.

All relevant employees receive training on modern slavery risks. Effectiveness is monitored through periodic review by Compliance and senior management, with material issues escalated to the Board or relevant committee.

During the reporting period, Liberis did not identify any substantiated instances of modern slavery or human trafficking within its own operations or supply chains.

This statement was approved by the Board of Directors 15 May 2026 and is published on Liberis’ website in accordance with section 54 of the UK Modern Slavery Act 2015.

Rob Fairfield, CEO