Modern Slavery Statement

1. Our Business

TP Commercial Finance Ltd (“TPCF”) is a technology and advisory company registered in England and Wales, with its registered office at 5 Garrick Street, London, WC2E 9AR. We operate the Loan Intel loan book intelligence platform, a SaaS platform providing cross-lender credit risk analytics and market intelligence to UK specialist lending institutions.

TPCF is a small business operating primarily in the technology and financial services sectors. Our workforce is based in the United Kingdom. We do not operate manufacturing, logistics, or other supply chains traditionally associated with elevated modern slavery risk. Our services are delivered digitally.

2. Our Supply Chains

As a technology business, our supply chains are relatively limited in scope and primarily comprise:

• Software and technology providers: Cloud infrastructure providers, software-as-a-service vendors, and development tools. These are predominantly large, publicly listed companies operating in regulated markets with their own modern slavery compliance obligations.
• Professional services: Legal advisors, accountants, and IT contractors engaged on a project basis. These are professional services firms operating under their own regulatory and ethical frameworks.
• Data providers: Licensed data providers including Companies House, HM Land Registry, and commercial data providers such as Experian. All are UK-regulated entities.
• Office supplies and facilities: Standard business supplies and facilities management services for our London office.

We assess the risk of modern slavery in our supply chains to be low, given the nature of our business, the jurisdictions in which we operate, and the regulated status of our principal supply chain partners. However, we remain committed to continuous improvement in our oversight.

3. Our Policies

We maintain the following internal policies relevant to our commitment to preventing modern slavery and human trafficking:

• Recruitment Policy: All recruitment is conducted through lawful channels. We verify the right to work in the UK for all employees before employment commences. We do not use recruitment agencies unless they are members of the Recruitment and Employment Confederation (REC) or equivalent accredited body.
• Supplier Code of Conduct: We expect all suppliers to comply with applicable laws, including those relating to employment rights, health and safety, and anti-slavery. This expectation is communicated in our supplier engagement process.
• Whistleblowing Policy: We maintain an internal whistleblowing mechanism through which employees and contractors can raise concerns about modern slavery or other unethical conduct, without fear of retaliation. Reports can be made to a designated senior manager or to an anonymous external reporting channel.
• HR and Employment Policy: All staff are employed under written contracts that comply with UK employment law. We pay at or above the National Living Wage for all roles and do not make deductions from wages that would reduce pay below minimum wage levels.

4. Due Diligence

During the year, we undertook the following due diligence activities:

• Reviewed our principal supply chain partners and confirmed that they each maintain their own Modern Slavery Act compliance statements where required by law
• Assessed the risk profile of our supply chains using the Home Office's modern slavery risk assessment framework
• Reviewed our standard supplier terms to ensure they include appropriate anti-slavery warranties and termination rights
• Confirmed that all TPCF employees have the legal right to work in the UK and are employed on terms that comply with the National Minimum Wage Act 1998
• Reviewed our recruitment processes to ensure we do not engage with any labour providers that do not comply with applicable employment law

5. Training

All TPCF employees receive induction training that includes an overview of modern slavery, how to recognise potential indicators, and how to report concerns. We include modern slavery awareness as part of our annual compliance training programme.

Management and procurement staff receive additional training on identifying modern slavery risk in supply chains and the due diligence steps expected when engaging new suppliers.

6. Measuring Effectiveness

We measure the effectiveness of our approach to preventing modern slavery through the following indicators:

• Number of employees completing annual compliance training (target: 100%)
• Number of supplier reviews completed against our Supplier Code of Conduct
• Number of whistleblowing reports received and investigated
• Maintenance of up-to-date supplier due diligence records

During the financial year ending March 2026, TPCF received no reports through its whistleblowing mechanism relating to modern slavery or human trafficking, and identified no instances of modern slavery in our business or supply chains. We continue to monitor and review our approach annually.

7. Board Approval

This statement has been reviewed and approved by the board of directors of TP Commercial Finance Ltd. It will be reviewed and updated annually.