Modern Slavery & Human Trafficking Statement

Atlantic Partners Asia Holdings (SG) Pte. Ltd and its affiliates and subsidiaries (“APA”, “we”, “us” or “our”) are committed to conducting our business ethically, responsibly and with respect to internationally recognised human rights.

APA HAS A ZERO-TOLERANCE APPROACH TO MODERN SLAVERY, HUMAN TRAFFICKING, FORCED LABOUR, SERVITUDE AND OTHER FORMS OF EXPLOITATION. WE ARE COMMITTED TO TAKING REASONABLE AND PROPORTIONATE STEPS TO IDENTIFY, PREVENT AND ADDRESS THE RISK OF MODERN SLAVERY AND HUMAN TRAFFICKING WITHIN OUR BUSINESS, OPERATIONS AND SUPPLY CHAINS.

This Modern Slavery and Human Trafficking Statement (“Statement”) sets out our approach to addressing these risks and the steps that we have taken and continue to take. It is made in accordance with the modern slavery and human trafficking laws applicable to APA and the APA entities within the APA Group, to the extent that those laws apply.

APA has multiple entities across various jurisdictions, some of which provide foreign exchange, currency and related financial services within the scope of their applicable licenses, authorisations and regulatory permissions, to approved businesses and individuals. Our business is primarily digital and technology-enabled and supported by a network of regulated financial institutions, technology providers and operational partners. We recognise that modern slavery risks may arise indirectly through our contractors, service providers, technology and software providers and other business relationships. Our supply chains consist mainly of regulated and professional service providers, including technology and software providers, banking and liquidity providers, payment processors and other corporate and professional service providers.

APA is committed to:

a) complying with applicable laws and regulatory requirements relating to modern slavery, human trafficking and forced labour;

b) respecting internationally recognised human rights;

c) not using or knowingly supporting forced, bonded or compulsory labour;

d) not using or knowingly supporting child labour;

e) treating employees and contractors and with dignity and respect;

f) maintaining appropriate standards for our suppliers and business partners; and

g) taking appropriate action where concerns relating to modern slavery or human trafficking are identified.

We expect our employees, contractors, consultants, suppliers and relevant business partners to share these principles.

While our sector is generally considered to present a lower risk of modern-day slavery than certain labour-intensive industries, we remain vigilant to the potential for modern slavery risks in our operations and supply chains. APA recognises that this risk can arise in a variety of circumstances, including through:

a) suppliers and outsourced service providers;

b) technology and software providers;

c) contractors and consultants;

d) jurisdictions or sectors with elevated human rights risks; or

e) the misuse of our services to move funds connected to modern slavery or human trafficking.

APA conducts risk-based due diligence on suppliers, business partners and relevant third parties, proportionate to the risks identified above. This may include, but is not limited to:

a) verifying the identity and ownership of relevant counterparties;

b) assessing the nature and location of the services provided;

c) considering the jurisdiction and sector in which a counterparty operates;

d) reviewing relevant policies, certifications or public disclosures;

e) considering adverse media and other available information;

f) conducting enhanced due diligence where particular risks or concerns are identified; and

g) maintaining appropriate frameworks, polices and procedures to ensure due diligence is conducted consistently.

APA also applies client due diligence, sanctions screening, transaction monitoring and suspicious activity reporting controls in accordance with the applicable laws. These controls also help us to identify and report activity that may be connected to modern slavery or human trafficking.

Where a supplier or business partner is found to have engaged in, facilitated or knowingly supported modern slavery or human trafficking, APA will take the appropriate actions, which may include suspending or ending the relationship and reporting the matter to the relevant authorities.

Our approach is supported by a framework of policies, procedures and controls designed to prevent modern slavery and human trafficking, including but not limited to our Whistleblowing Policy, Anti-Money Laundering Counter Terrorism and Anti Proliferation Policy, and our outsourcing frameworks.

We are also committed to maintaining a workplace that is respectful, inclusive and free from any form of forced or exploitative labour. All employees, contractors or consultants engaged by APA are subject to fair recruitment processes, right-to-work checks and clear contractual terms.

Employees involved in procurement, onboarding and risk management will receive training on modern slavery risks and on how to identify and escalate concerns.

We monitor the effectiveness of these measures through ongoing oversight, internal governance and periodic review of our policies and procedures, and we review this statement at least annually.

This statement was approved by the Board of Directors and will be reviewed at least annually, or more frequently if required by law or changes in APA’s operations.