Executive Summary:

As a regulated payment services provider, ESG is not a peripheral corporate responsibility but integral to our regulatory posture, risk framework, and long-term enterprise value. The FCA increasingly expects firms to evidence effective governance, robust risk management, operational resilience, and fair customer outcomes; all of which intersect with ESG. Environmental and social factors influence counterparty risk, fraud patterns, financial crime exposure, and customer vulnerability, while governance quality directly affects conduct risk, safeguarding compliance, and systems and controls. Investor, client, and partner due diligence now routinely incorporates ESG assessment, meaning our positioning in this area has direct implications for funding access, commercial partnerships, and brand trust.

The Board should therefore consider ESG through a prudential and strategic lens:

(i) Clear Board accountability and oversight, including integration into the risk appetite statement;

(ii) Identification and management of climate, operational resilience, and third-party concentration risks;

(iii) Alignment with FCA expectations on Consumer Duty and anti-financial crime controls;

(iv) Transparent disclosures proportionate to our scale.

ESG should be embedded within our enterprise risk management, product governance, and remuneration structures rather than treated as a standalone initiative.

As you are aware, many ESG-related principles are already embedded within our existing frameworks, including – but not limited to - our Risk Appetite Statement, Operational Resilience programme, and Consumer Duty implementation. However, we have not yet articulated this coherently to our staff or to external stakeholders. I therefore propose that we formalise our position through a clear ESG statement published on our website and supported by internal communications to enhance staff awareness and accountability.

The proposed statement will be proportionate to the size, maturity, and capabilities of the business, reflecting our current operating model while establishing a foundation for future development. It is intended as a structured baseline rather than a static declaration, with scope to expand in line with regulatory evolution, stakeholder expectations, and the continued growth of the organisation.

Statement:

We believe that access to safe, affordable, and easy-to-use financial services is a fundamental requirement for participation in the modern economy. As an FCA-authorised payments and fintech organisation, we are committed to building a responsible business that contributes positively to the community.

Environmental Responsibility:

Although our environmental footprint is relatively small as a digital-first fintech, we actively take steps to minimise our impact by:

• Operating a hybrid working model, helping to reduce commuting emissions.

• Reducing office waste through digital documentation, e-signatures, and paper-free processes such as online statements.

Social Responsibility:

We recognise our responsibilities and strive to meet them through:

• Supporting individuals, businesses, and communities who may face barriers to accessing financial services.

• Prioritising transparency, clear communication, and responsible product design to ensure customers understand our services and the potential risks of those services.

• Providing a safe, diverse, and inclusive workplace with equal opportunities for professional growth.

Governance:

Good governance is fundamental to how we operate as a regulated fintech. We aim to achieve this by:

• Maintaining a strong compliance culture aligned with regulatory expectations in all jurisdictions where we operate.

• Implementing clear internal controls, risk management frameworks, and robust policies to prevent financial crime, bribery, corruption, and unethical behaviour.

• Transparent reporting to stakeholders, consistent with our size and regulatory obligations.

• Communicating key decisions through established management structures, such as Management meetings and Board meetings to direct the business accordingly.

Our Ongoing Commitment:

As customer needs, regulatory expectations, and technology change, so will our approach. We will:

• Review this statement annually,

• Update our initiatives, partnerships, and metrics as necessary.

By embedding inclusion in our culture, operations, and services, 3S Money Group is committed to helping build a fairer, more accessible financial system for everyone.