Tide Modern Slavery Act Statement 2022

Our inclusive #OneTeam culture is at the heart of our business, and we strive to reflect the diversity of members we serve. We understand our responsibility to ensure fairness for all goes much further than this, and as part of our due diligence, we make every effort to ensure slavery and human trafficking are not present in our business or supply chains.

Tide is committed to upholding fundamental human rights and supports the underpinning principle set out in the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work, namely: freedom of association and the effective recognition of the right to collective bargaining, the elimination of forced or compulsory labour, the abolition of child labour and the elimination of discrimination in respect of employment and occupation.

We have a zero-tolerance policy to slavery, servitude, forced labour, or human trafficking - all of which are defined as 'modern slavery'. As a business, we are committed to creating and continuously improving systems and controls which prevent modern slavery; within Tide, we work to increase our employees’ understanding of these important issues, and outside of the business, we also work closely with regulators and law enforcement to help identify modern slavery in the communities we operate in.

In our statement, you will find our actions taken to understand all the potential modern slavery risks related to Tide, and the steps made to prevent it during the 2022 financial year. This is our second Statement on Modern Slavery and Human Trafficking, published in accordance with the Modern Slavery Act 2015, and includes our subsidiary Tide Platform Ltd.

About Tide

Tide’s mission is to save time and money for people who work for themselves so that they can get back to doing what they love - running their businesses. Focusing on small and medium-sized companies that are the lifeblood of the economy, we want to do all we can to support them and help them to grow. Tide serves over 500,000 customers and has more than 1,000 employees across our offices in London, Sofia, Hyderabad and New Delhi. Given the nature of our business, we believe there is a very low risk that modern slavery and human trafficking are present in our supply chains or within the company.

That being said, we acknowledge that these are real, yet hidden, issues in our society and, in a time of compounding crises, are likely to rise over the coming years. At Tide, we do not tolerate these human rights violations, and therefore make every effort to ensure that our business and supply chains are free of modern slavery.

Tide’s Board and the Executive Management Team maintain transparent relationships with the regulators, which ensures our strategic aims are in line with our regulatory obligations, board members are subject to FCA’s Senior Managers and Certification Regime Conduct Rules and are screened for Conflict of Interests.

Our governance framework allows for effective flow of information through appropriately structured executive committees. Key issues, including those related to human rights, modern slavery and human trafficking, may therefore be raised through these channels to the Board.

Our Key Values & Ethics

At Tide, the values we live by every day are to put our members first, work as one team and be data driven. These values are key to every decision made and the way each of us goes about our daily work. Our passion for supporting these businesses is at the centre of all we do; it drives our business ambitions, our values and our ethics.

Putting our members at our heart

We connect with our members regularly to understand their needs and how they are feeling. We ask how they are using the product, what more we could offer them, and about any challenges their business is facing. This helps us to improve our products and build new ones to make Tide as useful as possible for our members, as well as ensuring we’re producing the right content, putting on the right events and engaging with our members in the correct way.

We champion our members, giving them a boost wherever we can, which encompasses our ongoing commitment to the Environmental, Social & Governance issues in business. For example, through our Member Spotlight series, we shed light on small businesses from all walks of life, including an eco-friendly florist, a recruitment platform promoting gender balance, and an eco-cushion cover designer. We partner with our members as suppliers to Tide wherever we can, and support our member charities where possible, for example, we recently raised money for Human Dignity Trust during our Pride at Tide month.

Tide is also a big supporter of women in business, committing to supporting 100,000 women in starting their own businesses by 2023. We’re doing this through providing advice and information, access to experts and mentoring amongst many other initiatives.

Tideans

Tide is committed to treating all staff fairly and equitably, helping them perform effectively and bring their whole selves to work. It is our aim that the rules and procedures should emphasise and encourage treating every employee with fairness, dignity, and respect. Fostering an inclusive culture, we do not tolerate discrimination, bullying, or harassment on any grounds as is set out in our Conduct Risk Policy, Disciplinary Policy and Policy on

Prevention of Sexual Harassment at Workplace.

Underpinning all of these policies, we want the voices of our employees to be heard. We are committed to maintaining an environment which ensures our employees can raise concerns without fear of retaliation. We encourage feedback and effective confidential channels for employee complaints, including our anonymous Whistleblowing reporting procedures.

Our Financial Crime Policies apply to all customers, employees and third parties, including suppliers. These policies, covering fraud, bribery and corruption, tax evasion, sanctions, money laundering and terrorist financing, are designed to mitigate the risk of initiating or continuing relationships with account holders or entities involved in criminal activity.

As perpetrators of Modern Slavery may generate profits that would be considered proceeds of crime, their actions may constitute money laundering predicate offences and could also be a source of terrorist financing. Public authorities may impose sanctions for human rights abuses including modern slavery, and we recognise that bribery and corruption can also contribute to such violations.

Continuous Training Programme

We are committed to training staff so they are fully equipped with the right tools and knowledge to be effective in their roles. All new joiners undergo financial crime training, which is refreshed annually. This training highlights the importance of identifying suspicious activity and reporting it.

Tide provides training, conducted by external subject matter experts, to the relevant teams on identifying signs of modern slavery or human trafficking in our members. We fully support the continuous learning and development of all staff by producing and updating training based on global news and trends. Employees are also encouraged to pursue external training courses and certifications.

We will continue to review the steps we are taking, and the controls and monitoring systems we have in place, to combat modern slavery and human trafficking. Our commitment is to make improvements to our policies and practices as necessary.

Tide Customers and Partners

Tide carries out due diligence on all of its member base; businesses and sole traders. Controls are built into our application to ensure the onboarded customer fits within Tide’s risk appetite. We have a proactive approach to identifying suspicious activity, and where necessary, take appropriate measures for member accounts if such activity is flagged.

Tide takes pride in our partner relationships and ensures all partners uphold the standards we have as a company. We request a copy of a modern slavery statement from our strategic partners, both at onboarding and as part of annual due diligence reviews, as standard.

Tide’s Supply Chains

Tide is committed to developing business relationships with high-quality suppliers and partners that are committed to operating under ethical and environmental standards equivalent to Tide’s own. This includes the fair treatment of customers, employees and other stakeholders.

Tide utilises services from third parties, predominantly located in the United Kingdom, United States, Europe and India. To tackle modern slavery in the supply chain we:

• Adopt a risk-based approach in identifying, monitoring and assessing suppliers who are at greater risk from instances of slavery/trafficking, making sure we take the appropriate mitigating actions.

• Perform due diligence and relationship oversight, in line with our Supplier & Outsourcing Policy and Third Party Management Procedure, ensuring vendors meet Tide’s expectations on an ongoing basis.

On the recommendation of the Board Risk & Compliance Committee, material outsourcing decisions are made by the Board, and the materiality of Tide’s outsourcing relationships is regularly monitored. Maintaining high standards of business conduct is key to Tide and we do not use vendors that violate labour laws.

Supplier and Outsourcing Policy

Tide has a Vendor Risk Management Policy and an Outsourcing Policy, which both outline our approach to supplier management and outsourcing. This helps us to ensure our suppliers and outsourced partners meet Tide’s expectations and comply with regulatory requirements.

Compliance with Section 54 of the Act

Since publishing our first Modern Slavery Statement in June 2022, we have had no employee reports or reports from the public or law enforcement agencies indicating that modern slavery practices are taking place in our supply chain.

Next Steps

In the next year we plan to continue to develop our commitment to preventing modern slavery by launching a new Modern Slavery and Human Trafficking Policy which will set out:

• Our standards for how we will work to prevent modern slavery and human trafficking in our supply chains. This will include looking at due diligence and contractual commitments with suppliers, partners and vendors, and how we will continue to re-review these relationships throughout the year.

• Incorporate anti-slavery obligations into agreements with suppliers where relevant and on a risk-assessed basis.

• Our ongoing commitment to increasing awareness throughout Tide with training and development for employees.

• How we will educate our members to identify the risks of modern slavery and human trafficking in their supply chains.

• Due diligence on recipients of Tide charitable donations to ensure the organisations are in line with Tide cultural values.

We will continue to review the steps we are taking, as well as the controls and monitoring systems we have in place, to combat modern slavery and human trafficking. Our commitment is to make improvements to our policies and practices as necessary.

Board Approval

This statement was approved by the Board of Directors of Tide Holdings Limited on 25 June 2023.

Oliver Prill CEO Date: 29 June 2023