Last updated

Financial Year 2025-2026

Introduction

Although Loyalbe Ltd ("LoyalBe") is not required to report under the Modern Slavery Act 2015, this statement is made voluntarily to demonstrate our commitment to ethical business practices and aligns with the principles of Section 54 of the Act. It sets out the steps that LoyalBe has taken and continues to take to ensure that modern slavery and human trafficking are not taking place within our business or our supply chains.

LoyalBe has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

Our Organisation and Business

LoyalBe is a Card Linked Offer (CLO) network headquartered in Belfast, Northern Ireland. We operate a B2B technology platform that connects brands with card networks, banks, and fintechs.

• Company Name: Loyalbe Ltd
• Registered Office: 18 Ormeau Avenue, Belfast, United Kingdom, BT2 8HS
• Company Number: NI650618

Our Supply Chains

As a software and technology service provider, our supply chains are relatively short and consist primarily of:

• Cloud infrastructure and data hosting providers (e.g., AWS).
• Software-as-a-Service (SaaS) platforms used for business operations (e.g., CRM, project management, accounting tools).
• Professional services (legal, accounting, and consultancy).
• Office facilities and related services in the UK, EU or USA.

We consider the risk of modern slavery within our direct business operations and supply chain to be low. However, we remain vigilant and expect the same high standards from all our contractors, suppliers, and business partners.

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our internal policies reflect our commitment to acting ethically and with integrity in all our business relationships. These include:

1. Recruitment Policy: We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
2. Whistleblowing Policy: We encourage all employees to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.

Due Diligence Processes

To identify and mitigate risk, we:

• Build long-standing relationships with local suppliers and make clear our expectations of business behavior.
• Use reputable and global technology providers (such as Microsoft, Google, etc.) who publish their own Modern Slavery statements and adhere to high ethical standards.
• Review the anti-slavery and human trafficking compliance of new material suppliers as part of our onboarding process.

Measuring Effectiveness

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

• No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
• We maintain a level of communication and personal contact with the next link in our supply chain where possible to ensure their understanding of, and compliance with, our expectations.

Approval

This statement has been approved by the Board of Directors of Loyalbe Ltd and will be reviewed and updated annually.

(For a signed copy of this statement, please contact help@loyalbe.io)