Komainu is making a voluntary Slavery and Human Trafficking Statement (this “Statement”) relating to section 54 of the Modern Slavery Act 2015 (the “MSA”).

 This Statement describes the steps Komainu is taking to tackle slavery or human trafficking in our business and in our supply chain.

 1.                OVERVIEW OF THE KOMAINU GROUP

 1.1                 Komainu is a leading digital assets custodian built by institutions for institutions. The Komainu group of entities is headquartered in Jersey and has a global presence including in London, Italy, Singapore and Dubai (the “Komainu Group”).

 1.2                 Komainu (Jersey) Limited, a Komainu Group entity, is regulated by the Jersey Financial Services Commission for Fund Services Business in classes ZH (custodian) and ZI (depositary) and is headquartered in St. Helier, Jersey.

 1.3                 Komainu MEA FZE, a Komainu Group entity, is regulated by the Dubai Virtual Assets Regulatory Authority as a Virtual Asset Service Provider for VA Custody Services (including custodial staking).

 1.4                 Komainu UK Limited, a Komainu Group entity, has an MLR registration with the UK Financial Conduct Authority with FRN 985974.

1.5                 Komainu Europe S.r.l, a Komainu Group entity, has an OAM registration (PSV130).

 1.6                 We are committed to ensuring that the highest standards are met within our business and our supply chain with regard to tackling modern slavery and human trafficking.

1.7                 As Komainu Group is a multi-jurisdictional group, it is committed to ensuring that modern slavery and human trafficking issues are considered at both a global and local level.

2.                KOMAINU SUPPLY CHAIN

 2.1                 The annual turnover for the Komainu Group is under £36 million. So although we are not required to make a statement under section 54 of the MSA, we are making this voluntary statement to show our commitment to ethical trading principles and to set out the steps we are taking to tackle modern slavery and human trafficking in our business and in our supply chains.

 2.2                 As a digital asset custodian, the predominant supply chains for Komainu are the purchase of professional services, business and IT supplies. Whilst we view the risk of modern slavery within our business and our supply chain to be low, we are nonetheless committed to ensuring there is no modern slavery or human trafficking in any part thereof.

 3.                POLICIES

 The Komainu Group has policies in place to support our commitment to tackling modern slavery and human trafficking, and that comply with applicable legal and regulatory requirements. This includes our Employee Handbook which describes the standards of conduct expected from Komainu employees; Anti-Bribery and Corruption Policy which describes how Komainu complies with the UK Bribery Act 2010; Whistleblowing Policy for the reporting of illegal conduct; Complaints Policy for responding to complaints received from clients, investors and other parties; and AML Policy which describes requirements in respect of money laundering, financial crime and the legal and regulatory obligations.

4.                PEOPLE

 Komainu has a robust recruitment process that includes appropriate checks on new employees before they begin their employment. A number of our employees are also members of professional bodies and are therefore required to comply with professional and ethical codes of conduct. Our employees are also provided with relevant training, both as new joiners and on an ongoing basis. This training ensures our employees’ awareness of requirements and expectations of them in their roles at Komainu, including in relation to tackling modern slavery and human trafficking, the prevention of money laundering and countering the financing of terrorism.

 5.                DUE DILIGENCE AND RISK ASSESSMENT

 5.1                 To help identify and monitor the risk of modern slavery and human trafficking in our business and in our supply chains we conduct due diligence checks. We vet potential clients to ensure that any issues relating to criminal enterprises, such as money laundering, are identified. Komainu only deals with reputable suppliers of goods and services.

 5.2                 We continue to review our approach to due diligence and the ongoing engagement and renewal of relationships in order to identify and mitigate risks.

 5.3                 This voluntary slavery and human trafficking statement is made in connection with section 54(1) of the Modern Slavery Act 2015, for the financial year ending 2023. It was approved by the board members on 9 November 2023.

KOMAINU HOLDINGS LIMITED

Date: 15 November 2023