Modern Slavery Statement

Organisation

This statement applies to all companies within and associated to Fleximize which is part of the Alterium Group of Companies (hereinafter referred to as "Fleximize", “we” or “us”) (referred to in this statement as ‘The Group’). The Alterium Group of Companies is made up of Alterium Limited (08621989), Fleximize Limited (07117447), Fleximize Capital Limited (09485920), Fleximize Services Limited (08871283), Fleximize Technology Services Limited (10381710) and Flexicard Limited (10223497). The information included in the statement refers to the financial year ending July 2024.

Organisational Structure

Alterium Limited is a private limited company incorporated in the United Kingdom on 24 July 2013. Our registered office is located at Holbrook House, 51 John Street, Ipswich, Suffolk, England, IP3 0AH. As a financial services holding company, Alterium Limited oversees various financial activities and investments. All operations are managed centrally from the Ipswich office. The Group is led by a Board of Directors.

Fleximize is committed to preventing modern slavery and human trafficking in all aspects of our business and supply chains. This statement outlines the steps we have taken and continue to take to ensure that modern slavery is not present in our operations or supply chain.

Our activities are conducted from a centralised office, and all client interactions are managed digitally or through direct business relationships.

The labour supporting Fleximize’s operations is based in the East Anglian region of the United Kingdom.

Definitions

Fleximize considers that modern slavery encompasses:

• Human trafficking;
• Forced work, through mental or physical threat;
• Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
• Being dehumanised, treated as a commodity or being bought or sold as property;
• Being physically constrained or having restriction placed on freedom of movement.

Commitment

Fleximize acknowledges our responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. Fleximize understands that this requires an ongoing review of both our internal practices in relation to our labour force and, additionally, our supply chains.

Fleximize does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to Fleximize in the pursuance of the provision of our own services is obtained by means of slavery or human trafficking. Fleximize strives to exceed the minimum standards required in relation to our responsibilities under relevant employment legislation in the United Kingdom.

Supply Chains

In order to fulfil our activities, Fleximize’s main supply chains include those related to professional services, financial technology, and business support including financial services providers, IT and software vendors, merchandisers, and office suppliers. These are primarily based in the United Kingdom and other regulated jurisdictions.

Fleximize operates within a relatively low-risk sector for modern slavery; however, we recognise the importance of maintaining vigilance within our supply chain.

Potential Exposure

Fleximize considers our main exposure to the risk of slavery and human trafficking to exist in supply chains, for example office supplies and merchandising.

In general, Fleximize considers our risk of exposure to slavery/human trafficking to be low. Nonetheless, we have taken steps to ensure that such practices do not take place in our business nor the business of any organisation that supplies goods and/or services to it.

Steps

Fleximize carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in our organisation or supply chains, including conducting a review of the controls of our material suppliers.

Fleximize has not, to our knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, Fleximize has taken the following steps to ensure that modern slavery is not taking place:

• Policies – we are dedicated to complying with applicable laws and regulations which help towards building our integrity and ensuring we do not directly or indirectly support modern forms of slavery or human trafficking. Relevant policies include:
  • Anti-Money Laundering and Counter Terrorist Financing
  • Anti-Bribery and Corruption
  • Data Protection and Privacy
  • Fraud
  • Equality, Diversity and Inclusion (EDI)
• These policies are monitored and reviewed annually.
• All staff complete training on Modern Slavery, Anti-Bribery, Anti-Money Laundering, and GDPR. Alongside this we monitor and review the effectiveness and implementation of our internal policies. These are completed and monitored annually.
• Recruitment and selection – conducting Right to Work checks to verify that all employees are eligible to work in the United Kingdom.
• Regular review of material suppliers’ commitment to against Modern Slavery.

Slavery Compliance Officer

The Group has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Group obligations.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

This statement was approved by the Board of Directors of Alterium Ltd on 07th May 2025 and is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and constitutes the Modern Slavery and Human Trafficking Statement for the year ending 31 July 2024. This statement was signed off by a Director of Alterium Ltd. on 07th May 2025.

Name: Peter Tuvey

Position: CEO