Modern Slavery and Human Trafficking Statement

Zilch Holdings Limited / Zilch Technology Limited
Modern Slavery and Human Trafficking Statement
Financial Year Ended 31 March 2026

1. Introduction

This statement is made pursuant to section 54 of the UK Modern Slavery Act 2015 and sets out the steps taken by Zilch Holdings Limited and its subsidiaries (together, “Zilch” or the “Group”), including Zilch Technology Limited, during the financial year ended 31 March 2026 to prevent modern slavery and human trafficking in our business and supply chains.

Zilch has a zero-tolerance approach to modern slavery in all its forms. We are committed to acting ethically and with integrity in our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place in our operations or supply chains.

2. Our Business and Structure

Zilch is a UK-headquartered, UK FCA-authorised direct-to-consumer payments and lending platform. We provide customers with flexible payment options through our app-based product and operate an advertising-enabled payments network. During the financial year ended 31 March 2026, the Group generated revenue of £110.3 million and gross profit of £54.5 million.

As at 31 March 2026:

  • The Group employed approximately 274 employees and contractors.
  • Zilch Technology Limited holds both consumer credit and payments licences from the UK FCA and are a principal member of Visa.
  • We operate an innovation and technology hub in Kraków, Poland.
  • We have corporate entities in the United States to support our international operations.
  • We have agreed to acquire AB Fjord Bank, a Lithuania-based bank that is authorised and regulated by the Bank of Lithuania and the European Central Bank (completion of the acquisition is subject to regulatory approvals, which are expected in the second half of 2026).  

3. Our Supply Chain

As a fintech platform, Zilch does not manufacture physical goods. Our supply chain primarily comprises service providers and technology partners.

Our key supplier categories include:

  • Technology providers (including cloud hosting, software, cybersecurity and IT services)
  • Payment processing and card network partners
  • Identity verification providers
  • Customer support and operational service providers
  • Professional services (legal, audit, consultancy)
  • Recruitment agencies and temporary staffing providers
  • Facilities management and cleaning
  • Office equipment and IT hardware suppliers

4. Risk Assessment

Zilch takes a risk-based approach to identifying and managing modern slavery risks.

In assessing our exposure, we consider:

  • The nature of services provided
  • Geographic location of suppliers and subcontractors
  • The use of agency or temporary labour
  • The complexity of supply chains
  • Country-level human rights risk indicators

Given the nature of our business, we assess the inherent risk of modern slavery within our direct workforce as low. However, we recognise that certain supplier categories — particularly outsourced operational services, facilities services and recruitment agencies — may present elevated modern slavery risks, particularly where services are delivered in higher-risk jurisdictions.

5. Policies and Governance

Zilch maintains a suite of policies and governance controls designed to prevent modern slavery and related human rights abuses, including:

  • Outsourcing and Procurement policies
  • Recruitment and HR policies promoting fair treatment and lawful employment practices
  • Whistleblowing Policy
  • Anti-Bribery and Corruption, Financial Crime and Anti-Money Laundering policies
  • Oversight of modern slavery risk sits between our Compliance, Risk, Legal and People functions, with reporting to senior management and the Board as appropriate.

6. Due Diligence and Controls

Supplier Due Diligence

Zilch conducts risk-based due diligence on third-party suppliers prior to engagement. This includes:

  • Risk-based screening of suppliers
  • Assessment of geographic and sector risk
  • Evaluation of supplier policies and controls
  • Contractual provisions requiring compliance with applicable anti-slavery laws
  • The ability to terminate relationships where material breaches occur

Suppliers are expected to operate in accordance with applicable human rights and labour laws and to maintain appropriate internal controls.

Customer Due Diligence and Financial Crime Controls

As a regulated financial services firm, Zilch maintains a comprehensive financial crime control framework, including robust customer due diligence processes. This includes identity verification measures designed to ensure customers are who they claim to be, incorporating enhanced verification technologies such as biometric “selfie” checks and other fraud prevention controls.

While we do not currently conduct transaction monitoring specifically for the purposes of detecting modern slavery or human trafficking, we recognise the evolving role that financial institutions can play in identifying potential indicators of exploitation. We are actively working to enhance our approach in this area and continue to assess how our financial crime systems may further support the identification and escalation of relevant risks.

We also engage with sector-wide initiatives and industry forums, including the FinTech Financial Crime Exchange and similar collaborative groups, to share insights and strengthen our understanding of emerging risks and best practices.

Where concerns are identified through our existing controls or reported via internal channels, they are escalated in accordance with our established procedures and, where appropriate, referred to relevant authorities.

Internal Reporting

Employees are encouraged to raise concerns through our whistleblowing channels. Reports may be made anonymously, confidentially and without fear of retaliation. All reports are investigated in accordance with our whistleblowing process.

7. Training and Awareness

Zilch provides mandatory compliance training to all employees, including training covering whistleblowing, financial crime, and escalation procedures.

Training completion is monitored on an ongoing basis as part of our compliance framework to ensure completion rates remain high. This is also reported to the Board periodically.

8. Measuring Effectiveness

To assess the effectiveness of our approach, we monitor:

  • Completion rates for mandatory compliance training on a quarterly and annual basis
  • Reports raised via whistleblowing channels relating to human rights concerns
  • Any identified incidents or escalations related to modern slavery risk

During the financial year ended 31 March 2026, we did not identify any confirmed instances of modern slavery within our business or supply chain.

We continue to review and enhance our controls as our business grows.

9. Continuous Improvement

Zilch is committed to continuously improving its approach to identifying and mitigating modern slavery risk. Planned actions include:

  • Implementing a third party risk framework
  • Ongoing refinement of supplier risk assessment processes
  • Periodic review of contractual protections
  • Continued enhancement of training and awareness
  • Monitoring regulatory developments in the UK, EU and US

10. Approval

This statement has been approved by the Board of Directors of Zilch Holdings Limited and Zilch Technology Limited on 19 March 2026 and is signed on their behalf by Philip Belamant, Director and the Chief Executive Officer.

Signed by:

Philip Belamant
Director
For and on behalf of Zilch Holdings Limited and Zilch Technology Limited