UK Modern Slavery Policy

MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT
FOR TONIO LIMTIED

A. INTRODUCTION

1. TONIO LIMITED company (hereinafter TONIO LIMTIED) is committed to improving its practices to ensure slavery and human trafficking are not taking place in any part of our business. TONIO LIMITED expects the same commitment from our suppliers, contractors and partners.

2. This statement sets out the steps TONIO LIMITED has taken to meet the requirements under the Modern Slavery Act 2075 (UK) and was approved by the Board of Directors of TONIO LIMITED on 01/05/2023.

B. ORGANISATIONAL STRUCTURE

3. Tonio Limited is a Private limited Company organized and existing under the laws of the UK, having its registered office at Suite 3 G & H, Docklands Business Centre, 10-16 Tiller Road, London, E14 8PXE 1 4 8 P X, UNITED KINGDOM.

4. The TONIO LIMITED principal activity is to give our customers new ways to manage money internationally, including sending and receiving money abroad.

5. None of our work is seasonal, nor do we work in certain sectors that have a higher risk of modern slavery. According to the UK government, these high-risk sectors include construction, food and drink, resource and mining or retail.

6. The Board of TONIO LIMITED is ultimately responsible for all relevant entities and ensures that all policies and procedures are sufficiently aligned.

7. This statement was prepared following input from and consultation with multiple teams including Legal, Third Party Risk Management, Compliance, and Privacy.

C. OUR APPROACH TO SLAVERY AND HUMAN TRAFFICKING

8. TONIO LIMITED is committed to ensuring that there is no modern slavery or human trafficking in the TONIO LIMITED's supply chains or in any part of our business. TONIO LIMITED acts ethically and with integrity in all our business relationships. TONIO LIMITED promotes and implements effective systems to ensure slavery and human trafficking are not taking place anywhere in our business or supply chains.

D. OUR SUPPLY CHAINS

9. The TONIO LIMITED has an extensive supply chain in order to power our business and help our customers.

10. Our suppliers support us in a wide range of areas including recruitment, compliance, marketing, technology, card production, facilities management and banking. We also have relationships with central banks and payment infrastructure services to efficiently run our business.

11. The majority of our suppliers are based in the UK, the EU.

12. In addition to carrying out initial due diligence of new suppliers, as summarised below, we reassess our critical suppliers on a periodic basis to ensure they continue to be the best fit for use.

E. DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

13. As part of our initiative to identify and mitigate risk, the TONIO LIMITED has in place processes to identify and assess potential risk areas in TONIO LIMITED and our supply chains and assess the effectiveness of such actions. These include:

• carrying out due diligence on new material suppliers, including an assessment as to whether the supplier or its supplier chain has a heightened risk of modern slavery. Additionally, during the due diligence process we query whether the Modern Slavery Act applies to such supplier and, if so, request a copy of their Modern Slavery Act statement in order to review the steps they have taken to prevent modern slavery in their business and their supply chains;
• monitoring potential risk areas in our supply chains by reviewing our relationships with suppliers on a periodic basis proportionate to their level of overall risk to the TONIO LIMITED;
• setting the bar high for the work we do and the way our employees behave. We have a Code of Ethics that sets out our minimum expectations of all customers. We show consideration and empathy, live by our values, and in this way we create an open, supportive culture where people can flourish, do their best work and feel supported to escalate concerns they may have about our business or suppliers. We're also clear on how we treat unacceptable behaviour, so we can continue to protect the culture we have built; and
• protecting whistleblowers through our Whistleblower Policy, which provides a confidential avenue for whistleblowers to submit disclosures anonymously if they wish in order to protect their identity.

14. TONIO LIMITED will not support or deal with any business to whom we know is involved in slavery or human trafficking.

F. SUPPLIER ADHERENCE TO COMPANY VALUES

15. TONIO LIMITED has a zero tolerance policy to slavery and human trafficking.

16. To ensure all those in TONIO LIMTIED's supply chain and contractors comply with our values, we have in place a supply chain compliance programme. This includes carrying out the due diligence process referred to above as to the potential level of risk of slavery and human trafficking for new material suppliers.

G. TRAINING

17. To ensure there is understanding of the risks of modern slavery and human trafficking in our supply chains and our business, TONIO LIMITED has training, ethics, disciplinary, and whistleblowing policies and procedures in place.

18. These policies and procedures allow and encourage TONIO LIMTIED to raise any concerns, and for TONIO LIMITED to take appropriate corrective action if necessary, including with respect to slavery or human trafficking.

H. ONGOING ASSESSMENT

19. On an annual basis, our senior management delegate a review of the effectiveness of the processes we have in place within the TONIO LIMITED to assess and address modern slavery and human trafficking risks. We also carry out internal audits which cover such compliance processes.