UK First Fintech Limited is committed to a work environment and supply chain that is free from human trafficking and slavery. For this reason the measures in the below modern slavery policy statements have been adopted.
Modern Slavery Policy Statements for UK First Fintech Limited Latest Statement:
1. Introduction and scope
This statement is made on behalf of UK First Fintech Limited (“UKFF”, the “Firm”, “we”, “our” or “us”) pursuant to
section 54(1) of the UK Modern Slavery Act 2015 (the “Act”). It sets out the steps we have taken during
the financial year ended 31 December 2025 to assess and address the risks of modern slavery and
human trafficking in our own operations and in our supply chains.
Modern slavery is a severe violation of fundamental human rights and includes slavery, servitude,
forced or compulsory labour, and human trafficking. UKFF has a zero-tolerance approach to all forms
of modern slavery and human trafficking and is committed to acting ethically and with integrity in all
our business dealings and relationships.
This statement covers UK First Fintech Limited and, where applicable, the activities carried out on its behalf within
the UK.
2. Our structure, business and supply chains
UK First Fintech Limited is a UK-regulated financial services fir. The Firm primarily serves Visa、Mastercard、Discover、American Express、JCB, UnionPay、Merchant. Our core activities
include:
• IBAN accounts
• prepaid cards
• One-stop platform for card processing, merchant service, e-wallet account service
UK First Fintech Limited operates from offices in the United Kingdom and employs staff in front-office, operations,
technology and support functions.
We are a provider of financial services and do not produce, manufacture or distribute physical goods.
As a result, our direct operational footprint is relatively low-risk for modern slavery. However, we
recognise that risks can arise, particularly in extended supply chains and in certain sectors and
geographies.
Our key categories of suppliers include (but are not limited to):
• IT hardware, software, cloud and telecommunications providers
• Providers of trading, market data, analytics and news services
• Building, facilities management and office services (including cleaning, maintenance and
security)
• Professional advisers (legal, accountancy, consultancy and other specialist services)
• Financial infrastructure and services (custody, clearing, settlement and other outsourced
operational services)
• Recruitment agencies and other contingent workforce providers
• Travel, accommodation and corporate events suppliers
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UK First Fintech Limited Modern Slavery Act Statement
March 2026
We acknowledge that certain categories – such as IT hardware manufacturing, facilities services, travel
and hospitality – can have higher inherent modern slavery risks in their upstream supply chains, even
where our direct supplier is a reputable and regulated business.
3. Policies and standards
UKFF’s approach to combating modern slavery is underpinned by our broader culture and control
framework, including policies that apply across the Firm and its supply chain. Relevant policies and
frameworks include:
• Code of Conduct and Ethics: Sets expectations that all employees act with integrity, comply
with applicable laws and regulations, and uphold high ethical standards in dealings with
clients, colleagues and third parties.
• Human Resources and Employment Policies: Ensure fair recruitment and employment
practices, including right-to-work checks, fair wages, non-discrimination, diversity and
inclusion, and protection against harassment and bullying.
• Whistleblowing / Speak-Up Policy: Provides confidential channels for employees and other
stakeholders to raise concerns (including concerns related to modern slavery or unethical
labour practices) without fear of retaliation, and outlines how such concerns are investigated
and escalated.
• Supplier and Outsourcing Standards: Set expectations that suppliers act consistently with
UKFF’s ethical standards, including compliance with the Act, and require suppliers to
implement appropriate controls within their own supply chains.
• Anti-Financial Crime Framework: Our anti-money laundering, sanctions, anti-bribery and
corruption and fraud prevention policies help reduce the risk that UKFF may be used to
facilitate criminal conduct, including that associated with modern slavery.
Where appropriate, we are enhancing our supplier-facing documentation (such as standard terms and
conditions, onboarding questionnaires and supplier codes) to more explicitly address modern slavery,
human rights and labour practices.
4. Governance and accountability
The Board of Directors of UK First Fintech Limited has overall responsibility for the Firm’s approach to modern
slavery risk and for approving this statement.
Day-to-day responsibility for implementing our modern slavery controls is shared across key functions,
including:
• Senior Management: Oversight of operational resilience, outsourcing, and conduct risks,
including modern slavery.
• Compliance and Risk: Advising on regulatory expectations, maintaining relevant policies,
supporting risk assessments and monitoring, and escalating issues to senior management and
the Board as appropriate.
• Finance / Legal / Operations: Managing supplier due diligence, contractual provisions and
ongoing oversight of key third-party relationships.
• Human Resources: Ensuring our employment practices are consistent with our zero-tolerance
stance on modern slavery and that relevant training is provided to staff.
Progress, emerging risks and material issues relating to modern slavery are reported to relevant
governance forums (for example, Risk and/or Management committees) as part of broader third-party
risk assessments.
5. Risk assessment and management
Based on our industry and the location of our operations, we assess the overall risk of modern slavery
within our direct business to be low. However, we recognize that pockets of higher risk may exist within
indirect supply chains, particularly in relation to facilities management (cleaning, catering, and
security) and IT hardware manufacturing.
To mitigate these risks, we remain vigilant and apply risk-based due diligence to screen and monitor
supplier relationships.
6. Looking Ahead
We understand that the risks associated with modern slavery are evolving. In the year ahead (2026),
UK First Fintech Limited will:
• Continue to review and enhance our internal procurement policies.
• Monitor regulatory developments, including emerging EU forced labor guidelines and
potential UK legislative updates, to ensure our compliance framework remains robust.
• Maintain our zero-tolerance approach to modern slavery across all business operations.
Approval
This statement has been reviewed and approved by the Board of Directors of UK First Fintech Limited.
Signed,
WEI FENGPING
UK First Fintech Limited
Date: 10 March 2026