Legal
Modern Slavery.
Our statement and policy on modern slavery and human trafficking. Questions? Get in touch.
Our statement and policy on modern slavery and human trafficking. Questions? Get in touch.
Vaultus voluntarily publishes this statement in the spirit of section 54 of the Modern Slavery Act 2015 (“the Act”), this statement outlines Vaultus Limited ("Vaultus") approach to modern slavery and human trafficking for the financial year ending 6 April 2026.
Vaultus is committed to preventing modern slavery and human trafficking in its operations and throughout supply chains. We recognise that modern slavery is a crime and a violation of fundamental human rights. This statement sets out the important actions taken during the last financial year to address risks in our business and supply chains, covering:
Organisation structure and supply chains
Policies in relation to slavery and human trafficking
Due diligence processes
Risk assessment and management
Key performance indicators
Training on modern slavery and trafficking
Vaultus, through its regulated partner Equals Money PLC and Equals Money Europe SA, provides international payment services, foreign exchange, and card solutions to both corporate and retail customers. Vaultus itself does not provide regulated services.
As of the end of the financial year 6 April 2026, Vaultus has 4 personnel based in the UK and Portugal consisting entirely of the Board of Directors. Our personnel are not at risk of modern slavery or human trafficking, our main focus has been on our supply chain.
Our technology is built and maintained by Equals Money PLC and Equals Money Europe SA ("Equals Money"), our card programme operated by Mastercard UK and Europe through Equals Money.
Beyond technology, Vaultus sources professional services, contractors, and consumables from suppliers of varying sizes, from small-to-medium businesses, and multinationals. These suppliers are based in the UK and Europe.
Vaultus recognises its responsibility to protect the rights and freedoms of its personnel, and individuals within its supply chains by implementing policies to mitigate and eliminate modern slavery and human trafficking risks. These policies are reviewed annually and include, inter alia:
Modern Slavery and Human Trafficking Policy
Anti-Bribery and Corruption Policy
Vaultus is committed to preventing and detecting modern slavery and human trafficking through continuous monitoring. Prior to entering any supplier relationship, Vaultus completes reasonable, proportionate Due Diligence checks to ensure they are compliant with applicable laws. Should a supplier fail to provide the necessary information or be deemed to be non-compliant, Vaultus will take appropriate actions, which may include terminating the relationship with that supplier.
Suppliers are required to inform Vaultus as to how they comply with the Act and how they will notify Vaultus should they have suspicion or knowledge of modern slavery or human trafficking that could impact their contract with Vaultus.
The Board is committed to strengthening and reinforcing Vaultus' stance on modern slavery and human trafficking, building upon the foundations laid out in the Modern Slavery and Human Trafficking Policy. Vaultus will ensure that all personnel hired in the coming financial year receive training on identifying and preventing modern slavery and human trafficking as part of their induction, with mandatory refresher training delivered annually.
In addition, Vaultus' board of directors continue to monitor and update modern slavery standards to ensure they reflect current best practices and regulatory requirements.
During the financial year ending on 6 April 2026, Vaultus had not received any reports relating to the knowledge or suspicion of modern slavery or human trafficking.
We believe an open and collaborative working environment is in the best interests of Vaultus, its personnel and its partners in the supply chain.
We will continue to evolve our approach to modern slavery and human trafficking and look forward to continuing this shared value.
Signed:
Kieran King
Co-Founder, Director
Adopted voluntarily by the Board of Directors · Last reviewed: September 2026 · Next review: September 2027
Vaultus Limited (“Vaultus”, “we”, “our”) is committed to acting ethically and with integrity in all our business relationships, and to preventing modern slavery, forced labour, servitude and human trafficking (together, “modern slavery”) in our own operations and in our supply chain.
Vaultus falls below the £36 million turnover threshold at which the Modern Slavery Act 2015 requires a statutory annual statement. We have adopted this policy voluntarily because we consider it good practice, and because our partners, including our regulated programme manager, expect it of businesses they work with.
This policy applies to:
All directors, employees, workers and contractors of Vaultus;
Everyone engaged in Vaultus’s recruitment and labour practices; and
Our supply chain, which for Vaultus is primarily technology and software vendors, professional and outsourced service providers, and physical card production and logistics suppliers. We do not operate a large physical supply chain.
Before entering a material supplier or partner relationship, we take reasonable, proportionate steps to satisfy ourselves that the counterparty does not engage in or tolerate modern slavery. This includes:
Basic checks on a supplier’s identity, jurisdiction and reputation before onboarding;
Including anti-slavery expectations in supplier contracts where appropriate; and
Raising concerns directly with a supplier, and ending the relationship where serious concerns cannot be resolved.
We review this approach periodically and will scale our due diligence as Vaultus and its supply chain grow.
We only engage staff and contractors who have the right to work in their jurisdiction, and we carry out right-to-work checks before engagement begins. We do not charge recruitment fees to candidates, employees or workers, and any recruitment costs are borne by Vaultus. All staff are free to leave their employment on reasonable notice and are not required to surrender identity documents or personal property as a condition of employment.
Anyone, staff, contractors, suppliers, customers or members of the public, who has a concern that modern slavery may be occurring in connection with Vaultus’s business or supply chain should raise it with the Board at complaints@vaultus.co.uk.
Vaultus will not retaliate against anyone who raises a concern in good faith, even if the concern turns out to be mistaken.
Relevant staff are made aware of this policy and of the signs of modern slavery as part of their induction, and the policy is available to all staff on request. We will introduce more formal training as the business scales.
This policy is owned by the Board of Directors of Vaultus Limited, which is responsible for its implementation and for reviewing it at least annually or sooner if our business or supply chain changes materially.
Approved by the Board of Directors of Vaultus Limited.
Date: September 2026
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