Modern slavery statement
Pursuant to Section 54 of the Modern Slavery Act 2015 (“the Act”), this statement outlines Equals Group Limited (“Equals”), Embedded Finance Limited (“Railsr”) and their subsidiaries (collectively, the “Group”) approach to modern slavery and human trafficking for the financial year ending 31st December 2025.
The Group is committed to preventing modern slavery and human trafficking in its operations and throughout supply chains. We recognise that modern slavery is a crime and a violation of fundamental human rights. This statement sets out the important actions taken during the last financial year to address risks in our business and supply chains, covering:
• Organisation structure and supply chains
• Policies in relation to slavery and human trafficking
• Due diligence processes
• Risk assessment and management
• Key performance indicators
• Training on modern slavery and trafficking
Our organisation
Across the Group, our regulated subsidiaries provide international payment services, foreign exchange, and prepaid card solutions to both corporate and retail customers. In addition, we deliver expense management solutions to businesses operating across a diverse range of sectors. The Group’s subsidiaries are authorised and regulated by the UK Financial Conduct Authority (FCA) and National Bank of Belgium (NBB).
The Group has approximately 550 personnel, with the majority based in the UK across our London and Chester offices, along with remote UK-based employees, representing around 75% of the total workforce of the Group. We also have employees abroad, including in South Africa, Poland, Malaysia, the Netherlands, Lithuania, Belgium, Luxembourg, France, and the United States of America. As our personnel primarily are employed at the Group-level and are not considered to be at risk of modern slavery or human trafficking, our main focus is on the supply chain of the Group.
Our supply chain
As a provider of user-centric technology to enable clients to make international payments, foreign exchange and card transactions in a low-cost manner, a significant proportion of the Group’s technology is built and maintained in-house. Nevertheless, the Group does utilise a supply chain where it is more practical to work with partners and suppliers to enable the day-to-day operations of our technology and products offering.
Beyond technology, the Group sources professional services, contractors, and consumables from suppliers of varying sizes, from small-to-medium businesses to multinationals. These suppliers are primarily located in the United Kingdom, the European Union with limited presence in other regions.
Our policies
The Group recognises its responsibility to protect the rights and freedoms of both its personnel and individuals within its supply chains by implementing policies that mitigate and eliminate modern slavery and human trafficking risks. These policies are reviewed annually and include, inter alia:
• Modern Slavery and Human Trafficking Policy
• Supplier Onboarding Policy
• Whistleblowing Policy
• Anti-Bribery and Corruption Policy
Our due diligence
The Group is committed to preventing and detecting modern slavery and human trafficking through continuous monitoring. All suppliers are required to complete Supplier Due Diligence and Security Questionnaires to ensure they are compliant with applicable laws. Should a supplier fail to provide a completed Questionnaire or deemed to be non-compliant, the Group will take appropriate actions, which may include terminating the relationship with that supplier.
Suppliers are required to inform the Group as to how they comply with the Act and how they will notify the Group should they have suspicion or knowledge of modern slavery or human trafficking that could impact their contract with the Group.
Our training
Throughout 2025 the Board has continued to strengthen and reinforce the Group’s stance on modern slavery and human trafficking, building upon the foundations laid out in the Modern Slavery and Human Trafficking Policy. Moving forward, the Group will continue to ensure that all personnel receive training on identifying and preventing modern slavery and human trafficking as part of their induction, with mandatory refresher training delivered annually.
In addition, the Group’s governance committees monitor and update modern slavery standards to ensure they reflect current best practices and regulatory requirements.
During the financial year ending on 31st December 2025, the Group had not received any reports relating to the knowledge or suspicion of modern slavery or human trafficking.
We believe an open and collaborative working environment is in the best interests of the Group, its personnel and its partners in the supply chain.
We will continue to evolve our approach to modern slavery and human trafficking and look forward to continuing this shared value across the Group.
Ian Strafford-Taylor
Chief Executive Officer
