Vitesse Anti-Slavery and HumanTrafficking Statement

This statement sets out the steps Vitesse has taken to prevent Modern Slavery and human trafficking occurring within any part of its business and supply chains. This statement is published in line with section54(1) of the UK Modern Slavery Act 2015 for the financial year ending 30 June 2026.

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About Vitesse

Vitesse is headquartered in the UK. Vitesse Holdings Ltd is the ultimate holding company for Vitesse Group. Vitesse PSP Ltd is regulated by the Financial Conduct Authority (Reference 900646) under the Electronic MoneyRegulations 2011 for the issuance of e-money.

Vitesse additionally has offices in the US, Vitesse TrustCompany LLC, and in the Netherlands, Vitesse PSP B.V.

Vitesse’s principal activity is providing a proprietary treasury management and payment service customised for the insurance sector, enabling major insurance organisations and their agents or administrators to hold, manage and disburse their insurance claims capital (claims loss funds or loss fund reserves) globally.

The commitments made in this document apply to all Vitesse Group entities.

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Vitesse’s commitment to the principles of the UK Modern Slavery Act 2015

Vitesse is committed to the principles of the UK ModernSlavery Act 2015 and the abolition of Modern Slavery and human trafficking.

We strive to act transparently, ethically and with integrity in all business relationships and to ensure slavery and human trafficking is not taking place anywhere within our business or supply chain. The firm has several policy areas to address this:

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Code of Conduct - serves to outline the behavioural expectations of all staff engaged by Vitesse.

Whistleblowing - It is the policy of Vitesse to encourage and develop a culture of openness and accountability within the firm. To achieve this, it is fundamental that any concerns that staff may have about suspected malpractice within the firm can be aired and dealt with effectively.

Supply Chain Management – Third-party risk management frameworks look to ensure robust governance of our suppliers and outsourcing partners, including managing the risk of modern slavery.

Recruitment Policies - Our recruitment and people management processes are designed to ensure that all prospective colleagues are legally entitled to work in the country they work with us in and to safeguard colleagues from any abuse or coercion.

We do not enter into business with any organisation, in theUK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour including child labour.

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Risks present within our business and supply chain

Vitesse has completed a risk assessment and, due to the nature of our business operations, we assess ourselves to have a low risk of UKModern Slavery in our business and supply chains.

As a medium sized business, our supply chains are relatively limited, with the majority being regulated banks or technology companies.

We operate a risk management process to review our suppliers on a regular basis, including reviews to flag any issues, operational or regulatory. This process provides us with confidence that there are no slavery or human trafficking taking place in any part of our business or in our supply chain. In addition, our approved suppliers are expected to adhere to standards, which requires suppliers to at all times comply with the provisions of the UKModern Slavery Act 2015 and includes an obligation that our suppliers and their subcontractors will employ a zero tolerance policy to forced or slave labour.

Vitesse will continue to monitor its adherence to its legal responsibilities through relevant key performance indicators.

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Training

We continue to provide awareness and training to staff on the policies relating to UK Modern Slavery Act 2015 and provide a safe space to report any suspected cases of slavery, human trafficking or other abusive behaviours.

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Conclusion

We have no cause to suspect that Modern Slavery is currently present within our business or supply chain, nor any evidence that it has been present in the past.

This Anti-Slavery and Human Trafficking Statement has been formally approved by the Vitesse PSP Ltd Board in September 2025.

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