Tide Modern Slavery Act Statement 2021

1. Statement

1.1. This statement is made pursuant to section 54 of the Modern Slavery Act 2015 (the “Act”) and sets out the steps Tide Holdings Limited on behalf of itself and its wholly owned subsidiaries (“Tide”) has taken during the financial year ending 31 December 2021 and will continue to take to ensure that modern slavery and human trafficking is prevented. This is Tide’s first modern slavery statement.

1.2. Tide has a zero-tolerance policy to slavery and trafficking in all its forms (including human, drug and sex trafficking and national wage violations). Slavery is a heinous crime and a morally reprehensible act, the proliferation of which is a serious violation of fundamental human rights. We recognise that any commercial organisation can be at risk of being involved in the various forms of modern slavery, through their own operations and supply chain

2. About Tide

Tide is a SME focused digital financial platform with over 400,000 customers. Tide has more than 900 employees across our offices in London, Sofia, Hyderabad and New Delhi.

Given the nature of Tide’s business, we believe there is a very low risk that modern slavery and human trafficking would be present in our supply chains or affect our business.

3. Our Policies & Training

Tide is committed to conducting its business in line with its ethical values, implementing effective systems and controls and acting with integrity and transparency.

Tide has a number of internal policies and procedures that reflect this commitment and are reviewed and updated as necessary to align with evolving best practices. We analyse and undertake investigative work to help enhance Tide’s ability to identify, monitor and disrupt methods used in criminal activity. This includes a number of systems and controls to highlight unusual or suspicious activity, which could indicate instances of modern slavery or human trafficking for further investigation. Any suspicion of financial crime, modern slavery or human trafficking is reported to law enforcement agencies as and when appropriate.

Whistleblowing Policy

We are committeed to conducting business with high standards of professionalism and integrity and we encourage all employees to report any concern including any suspicion of slavery or human trafficking without fear of retaliation. We provide internal confidential reporting, and access to a dedicated external helpline to protect the identity of whistle-blowers, managed by Lighthouse.

Vendor Risk Management Policy

We conduct due diligence on all new and existing vendors at regular intervals with the aim of addressing risks posed with respect to those relationships, including with respect to modern slavery or human trafficking in the supply chain.

Training

We are committed to training staff so they are fully equipped with the right tools and knowledge to be effective in their roles. All new joiners undergo financial crime training, which is refreshed annually. This training highlights the importance of identifying suspicious activity and reporting it. Tide provides training, conducted by external subject matter experts, to the relevant teams on identifying signs of modern slavery or human trafficking in our members. We fully support continued learning and development of all staff, where training is produced and updated based on global news and trends, and staff are also encouraged to pursue external training courses and certifications.

4. What’s Next

In the next year we plan to develop our commitment to preventing modern slavery by launching a new Modern Slavery and Human Trafficking Policy which will set out:

• Our standards for how we will work to prevent modern slavery and human trafficking in our supply chains, including looking at due diligence and contractual commitments with suppliers.

• Our ongoing commitment to training and development of employees.

• How we will educate our members to identify risks of modern slavery and human trafficking in their supply chains.

We will continue to review the steps we are taking, and the controls and monitoring systems we have in place, to combat modern slavery and human trafficking, and are committed to making improvements to our policies and practices as necessary.

5. Compliance with Section 54 of the Act

No reports from employees, the public or law enforcement agencies have been identified to indicate that modern slavery practices are taking place in our supply chain.

6. Board Approval

This statement was approved by the Board of Directors of Tide Holdings Limited on 29 June 2022.

Oliver Prill CEO 1 July 2022