Modern Slavery and Human Trafficking Statement

According to the Constitution which prohibits slavery at article 10. Section 370 of the Penal Code prohibits buying or disposing of people as slaves, section 371 prohibits habitual dealing in slaves and section 367 prohibits kidnapping or abducting in order to subject a person to slavery. Slavery may also form an element of an offence of trafficking under articles 3 and 4 of the 2014 Prevention of Human Trafficking Act. (the "Act"), Trust Financial Data Pte.Ltd. is required to publish this statement. It serves as the company's slavery and human trafficking statement for the fiscal year beginning on January 1, 2023, and ending on December 31, 2023. Together, these entities are referred to as the "TrustFinance"

Slavery and human trafficking are not tolerated in the supply chains or business operations of TrustFinance.

Business overview

TrustFinance was founded in 2022 with a vision to build trustworthy financial companies. We are a digital platform bringing businesses together to build trust and inspire collaboration. We are open to everyone and built on transparency for businesses and consumers.

TrustFinance hosts reviews to help financial companies with confidence, and deliver the deepest insights to help companies improve the experiences they offer. Many investors use our platform and share their own opinions, the deepest insights we offer companies, and the more opportunities they have to earn the trust of investors from all around the world.

The TrustFinance has over 20 employees and is headquartered in Singapore.

Organisational structure & supply chains

Trust Financial Data Pte.Ltd. was incorporated on 1 December 2022 and as part of TrustFinance’s initial public offering became the ultimate parent company in the TrustFinance Group, which is a limited liability company registered in Singapore.

As at the date of this statement, the TrustFinance employs over 20 employees and operates globally across the UK and APAC. Subsidiaries which form part of the TrustFinance and are also covered by this statement are:

• Singapore : Trust Financial Data Pte.Ltd.
• British Vergin Island : TFN Provider Service Ltd.

As a SaaS business, our people, expertise and intellectual property rights are our business. Although we engage with suppliers for a range of services, the majority of our suppliers provide us with IT hardware, network services, and software. Our business model therefore does not carry with it a high level of slavery risk.

Our approach

The TrustFinance works to uphold the greatest professional standards and to abide by all laws, rules, and guidelines that are pertinent to our industry.

In order to help guarantee that the purposes and terms of the Act are complied with and to address any issues or violations, our People (HR) and Legal teams collaborate with our Vendor Management (procurement) activities.

Customers, vendors, and contractors that work with us are expected to adhere to our modern slavery code of conduct. We try to impose contractual duties on suppliers to abide by this as part of contractual talks for supply contracts, and it is publicly available on our website.

All TrustFinance employees are subject to suitable pre-employment screening as part of our recruiting and employment procedures, which also includes reference and right to work checks. In addition, new hire training and induction sessions cover TrustFinance policies and confirm that employees can contact our People team or our whistleblower email account in confidence about any concern they may have at any time throughout their employment.

In all of our locations in Singapore, we are also committed to paying the Real Living Wage to all of our employees and contractors.

According to our Global Anti-Corruption and Bribery Policy, we have a zero tolerance policy for anti-corruption and bribery and expect all TrustFinance personnel to do business with honesty and integrity.

Our commitment to conducting business in accordance with the highest ethical standards is outlined in our code of ethics. The entire TrustFinance places a high priority on building trust, promoting transparency, and making decisions that are ethically sound. As a result, we expect everyone who works with us and conducts business with us to uphold these values at all times.

We avoid doing business with organizations that harm people or the environment, do not adhere to our moral principles, or do not hold the same values and fundamental beliefs as us. These "bad-fit" companies could damage TrustFinance's reputation and call into question the reliability of our platform. What types of companies we consider to be a "poor fit" for TrustFinance are outlined in our Action We Take Policy. We also outline the steps we'll take to halt all ongoing communications and collaboration with "bad-fit" companies.

In addition, as stated in our Terms of Use & Sale for Businesses, we expect customers to abide by our Modern Slavery Code of Conduct.

TrustFinance policies

To detect and stop any instances of slavery or human trafficking within our operations, the TrustFinance has policies in place. High professional and ethical standards are something we strive to uphold, and we make sure all of our staff members understand their part in doing so.

All TrustFinance employees receive a written employment contract that includes the TrustFinance Code of Ethics, and they are subject to corporate rules that are posted on the TrustFinance intranet. These include the Speaking Up Policy, the Bad-Fit Policy, the Global Anti-Bribery Policy, the Contract Approval & Signing Matrix, and the Non-Discrimination & Anti-Harassment Policy.

On TrustFinance's website, our Modern Slavery Code of Conduct is accessible to all suppliers, clients, and contractors.

Due diligence/Risk assessment

We look for clients, employees, and suppliers who are compatible with and supportive of our moral principles and organizational values.

The following indicators, which are commonly recognized to increase risk likelihood, have been used to identify sectors and categories with significant modern slavery risks:

• Reliance on unskilled labor
• Dependance on a mobile workforce
• The presence of kids.
• Unattractive or risky work
• Based in a nation with a history of high levels of corruption, bad leadership, and lax human rights enforcement.

Since TrustFinance is an online company, our primary suppliers are companies that offer online services to support our platform and general consulting services from well-known companies. We estimate that there is a minimal chance of modern slavery in our supply chain based on these facts.

We continue to:

• Do your research before choosing our supplier and contractors.
• Review the suppliers and employees we hire on a regular basis.
• Establish commercial ties with suppliers who share our company's principles.
• In particular, when we consider a supplier or contractor to be medium to high risk due to their location or another factor, we try to make sure that their supplier contract has a section addressing ethical treatment. This is done to make sure that the working conditions and surroundings they offer to their staff adhere to the principles set forth in our Modern Slavery Code of Conduct.

We reserve the right to sever ties with a supplier or contractor if they fall short of our standards or refuse to adapt.

Covid-19

We are aware of the difficulties caused by the Covid-19 epidemic and are keeping an eye on our risks at this time. We are devoted to putting our employees' health and safety first. Given the nature of our business and the locations of the majority of our vendors, we believe that the dangers associated with modern slavery in our supply chain have not grown during this time.

Further steps

In order to continue reducing the danger of modern slavery in our supply chains, the TrustFinance will be aiming to implement specific steps going forward. These will include:

• We will soon make modern slavery-specific training mandatory for all TrustFinance employees involved in hiring people and selecting contractors so they can recognize risk factors, comprehend the ramifications, and help us properly fulfill the Act's requirements.
• Acquiring a legal right to request information on compliance and the freedom to audit providers as we see fit.
• Ensuring that risk areas are tracked, documented, and taken into account in any upcoming contract extensions.

The Trust Financial Data Pte.Ltd. Board of Directors approved this statement on November 18, 2022, and it is signed by

Mr. Piyathanan Buramnithichot (also know as Peter Bu)

Chief Executive Officer

Trust Financial Data Pte.Ltd.