Modern Slavery Statement

Atom Group Modern Slavery and Human Trafficking Statement 2025

It continues to be a priority for both Atom Holdco plc and Atom bank plc (“Atom”, “we”, “us”, “our”) to have a zero-tolerance approach to any form of modern slavery or human trafficking. This extends to all aspects of our business and supply chain. This statement affirms that we are committed to acting ethically and responsibly, with integrity and transparency, in all business dealings.

Our Organisation and Business

Atom Holdco plc is a public company incorporated and registered in England and Wales under the Companies Act 2006. The principal activity of Atom Holdco plc is to act as the holding company of the Group (the “Group” being Atom Holdco plc and its consolidated subsidiaries). The main operating company of the Group is Atom Bank plc. Atom Bank plc is a financial institution, regulated by the Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA), which provides financial services to customers. Our headquarters are situated in North East England, with a second office location in London, England. We have a team of approximately 554 employees and manage approximately £5.3bn loans, as of 31/03/2025. We do not manufacture or supply any goods.

Our People

We are dedicated to operating our business in an open, transparent, and ethical manner where all employees feel comfortable raising questions or concerns. Before starting work, all Atom employees undergo mandatory pre-employment background checks, consistent with our Vetting Policy, and their right to work in the UK is established. Pre-employment background checks include identification checks, financial crime checks, reference checks, employment eligibility checks, sanctions checks, adverse financial checks, CIFAS checks and criminal record checks. All our employees have a written contract of employment.

Our Policies

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We have various policies in place that show our continuous commitment to acting ethically and with integrity in all our business relationships, as well as creating and enforcing effective systems and controls to ensure that slavery and human trafficking do not take place at any point within our supply chains or in our business. Our policies are reviewed and updated on an annual basis. These include, but are not limited to:

  • Procurement and Third Party Risk Management Policy
  • Whistleblowing Policy
  • Vetting Policy
  • Dignity at Work Policy
  • Working Hours Policy
  • Grievance Policy
  • Anti-Bribery and Corruption Policy
  • Fraud Prevention Policy

To ensure a high level of understanding of our policies we provide mandatory training and e-learning to our staff in areas that are relevant to them. All new joiners complete this training as part of their induction, with refresher training conducted annually for relevant teams.

Our Supply Chain

Third party service providers are fundamental to our ability to offer banking services and products to our customers. We maintain a zero tolerance approach to modern slavery and human trafficking across our supply chains. We recognise that the complexity of modern supply chains necessitates continuous vigilance and we have implemented rigorous controls to mitigate the risk of modern slavery and human trafficking. These measures allow us to:

  • proactively identify, assess, and manage potential risk areas in both new and existing third party relationships.
  • continuously monitor for any potential risks and issues, by maintaining robust governance, control, and oversight of our third party relationships.
  • ensure whistleblowers are protected.

Third Party Risk Assessment and Due Diligence

We conduct risk assessments and due diligence on our suppliers both when onboarding new suppliers and then on a periodic basis in line with the inherent risk of a service . This process, underpinned by our Procurement and Third Party Risk Management Policy, helps us to proactively identify potential risks and confirm supplier compliance with our policy requirements. We are committed to continuously maturing our assessment methodologies to include key and emerging risk areas. For 2025, we have updated our supplier due diligence framework to include an enhanced focus on Environmental, Social, and Governance (ESG) risk factors. This includes assessing suppliers’ ethical history and the adequacy of their modern slavery prevention measures.

Supplier Code of Conduct

Our Supplier Code of Conduct outlines the ethical, social, environmental and legal standards that Atom expects its suppliers to adhere to. The code is shared with our suppliers on an annual basis and suppliers must attest to their adherence to it. The code has been refreshed for 2025 and includes explicit expectations that suppliers prohibit child labour, forced labour and modern slavery, both in their own organisation and their supply chain. Beyond requiring our suppliers to attest to this code we monitor compliance with these requirements through ongoing monitoring and oversight over our suppliers.

Contracting with Third Party Providers

Where appropriate, compliance with all applicable laws, including modern slavery regulations, forms part of any contract that we agree with our material third party providers. Atom will only deal with third parties where it is satisfied the third party operates in a manner consistent with Atom’s core values, including the prevention of modern slavery.

Monitoring Third Parties

We have well defined and embedded ongoing monitoring and oversight requirements for our supplier relationships. This includes continuous performance monitoring, periodic risk assessments, enhanced due diligence reviews and proactive financial and adverse media monitoring. These activities are supported by robust reporting and governance mechanisms, enabling us to comprehensively assess the adequacy of our third parties’ control environment and identify any potential risks and issues, including those related to modern slavery. We are pleased to report that no concerns or issues related to modern slavery were identified within our supply chains during the 2024/2025 financial year, which affirms the effectiveness of our control environment.

Our Ongoing Commitment

We are committed to regularly reviewing and enhancing our approach to combating modern slavery and human trafficking. To ensure ethical conduct throughout our operations, we will continue to cultivate strong relationships with our external suppliers and partners. We will actively engage with them on matters concerning modern slavery and human trafficking, ensuring their ethical practices and values consistently align with Atom's high standards. Should any issues be identified, we will take appropriate action through governance and oversight channels.

Approval

This statement is made pursuant to s. 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year 2024/2025. Atom’s financial year ends on 31 March and this statement was approved by the Board of Directors on 10 July 2025.

LEE ROCHFORD, CHAIRMAN

ATOM BANK

10 July 2025