Modern Slavery & Human Trafficking Statement

1. Introduction
Bonsai Wealth Ltd (“Bonsai”) is committed to preventing modern slavery and human trafficking across all parts of our business and supply chain. While Bonsai operates within the financial technology sector - a field considered low risk for labour exploitation - we recognise our responsibility to identify, prevent, and address any potential risks related to modern slavery.

This statement is published pursuant to Section 54(1) of the Modern Slavery Act 2015 and outlines the steps Bonsai is taking to prevent slavery and human trafficking within its business and supply chains.

2. Our Business
Bonsai is a UK-based digital wealth platform providing financial planning, investment, and savings solutions to individuals. Our services are delivered through a combination of AI-powered technology, human oversight, and partnerships with regulated custodians and savings providers, including Seccl and Bondsmith.

Our business does not manufacture goods or operate within high-risk industries, but we remain vigilant in our third-party engagements and internal policies to ensure that human rights abuses are neither present nor tolerated.

3. Our Supply Chain
Bonsai’s supply chain primarily consists of:

• Technology service providers (cloud hosting, software development, data analytics);

• Financial services partners (investment platforms, savings providers);

• Professional services (legal advisers, consultants, marketing agencies);

• Operational suppliers (office space, IT equipment, and support services).

While these suppliers are predominantly based in the UK and other low-risk jurisdictions, Bonsai takes proactive steps to ensure all our partners operate ethically and in compliance with relevant laws, including those addressing labour rights and human trafficking.

4. Policies and Governance
We have implemented a range of policies to ensure ethical standards are upheld within Bonsai and by our suppliers, including:

• Supplier Code of Conduct – Outlines our expectations regarding labour standards, including compliance with the Modern Slavery Act.

• Procurement Policy – Ensures due diligence is conducted before engaging any supplier, including a review of their modern slavery commitments.

• Speaking Up Policy – Provides a confidential whistleblowing process allowing employees, suppliers, or other stakeholders to report any suspected modern slavery or human rights breaches.

• Employee Code of Conduct – Sets clear expectations for employee behaviour, including acting ethically in all business dealings.

• Recruitment Policy – Ensures all recruitment follows transparent, legal processes with appropriate checks to prevent forced or illegal labour practices.

5. Risk Assessment and Due Diligence
Given our business model and location, Bonsai’s direct exposure to modern slavery risks is low. However, we actively monitor and assess risks in the following areas:

• New supplier onboarding – All new suppliers undergo due diligence checks, including a review of their modern slavery policies if they are required to publish one.

• Third-party technology providers – We assess whether offshore suppliers or sub-contractors operate in higher-risk jurisdictions.

• Operational suppliers – For any non-financial suppliers (e.g., facilities management), we verify they comply with UK employment standards.

Where risks are identified, Bonsai will either work with suppliers to improve standards or terminate relationships if compliance cannot be achieved.

6. Employee Training and Awareness
All Bonsai employees receive mandatory training on:

• The Modern Slavery Act 2015 and how it applies to our business.

• Recognising signs of forced labour or exploitation in business relationships.

• Reporting concerns through our Speaking Up process.

Modern slavery awareness forms part of wider training on ethical business conduct delivered to all employees annually.

7. Performance Monitoring and Continuous Improvement
Bonsai monitors its modern slavery risk management performance through:

• Annual reviews of our supplier due diligence process.

• Tracking completion rates for employee training.

• Keeping an up-to-date Modern Slavery Risk Register for high-risk suppliers.

• Ongoing review of regulatory changes and best practice updates.

We are committed to continuous improvement, and as the business grows, we will expand the scope and depth of our monitoring processes to match the evolving risk landscape.

8. Approval and Publication
This statement has been approved by the Board of Directors of Bonsai Wealth Ltd and will be reviewed annually to ensure it reflects the business’s ongoing commitment to preventing modern slavery.

This statement is published on our website and forms part of our broader commitment to ethical business conduct.

Date: 1 March 2025