Our commitment

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and describes the steps taken by LHV Bank Limited during the financial year ended 31 December 2025 to identify, prevent and manage the risk of slavery and human trafficking in our business and supply chains.

Modern slavery is a serious crime and an abuse of fundamental human rights. We are committed to acting responsibly, improving transparency and strengthening our approach over time. We do not tolerate slavery, servitude, forced or compulsory labour or human trafficking in our operations or supply chains.

1. Our organisation

LHV Bank Limited is incorporated in England and Wales and is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. The Bank provides retail banking, SME lending and Banking Services to financial institutions. LHV Bank Limited is part of AS LHV Group, headquartered in Estonia.

Our direct operations are principally based in the United Kingdom and are delivered by a professional workforce. Our supply chains support the operation and development of the Bank and include:

• technology, cloud, software, telecommunications and IT infrastructure providers;

• professional services, including legal, audit, consultancy and specialist advisory services;

• facilities management, cleaning, security, maintenance and office services;

• recruitment agencies, contractors and temporary labour providers;

• payment, operational and other outsourced or intra-group service providers; and

• office equipment, technology hardware, marketing, printing and other business-support suppliers.

2. Governance and responsibilities

The Board is responsible for approving this statement and overseeing the Bank's approach. Operational responsibility for supplier selection, contracting and ongoing management sits with the relevant business and supplier owners. Compliance provides advice, oversight and challenge, and the Bank's whistleblowing arrangements provide a confidential route through which concerns may be raised.

Modern slavery risk is considered through the Bank's broader governance arrangements for conduct, financial crime, employment practices, procurement and third-party risk management. Material concerns would be escalated to the appropriate accountable executive and governance forum.

3. Policies and control framework

The Bank's framework is supported by policies and controls that address ethical conduct, third-party risk and the escalation of concerns. These include:

• the Code of Conduct, which sets standards of integrity and behaviour expected of employees;

• confidential whistleblowing arrangements available for the reporting and escalation of concerns;

• third-party risk and supplier-management controls covering the selection, due diligence, approval and oversight of material suppliers;

• financial crime policies and procedures supporting the identification and reporting of suspected criminal exploitation, including human trafficking; and

• contractual and legal-compliance expectations applied to suppliers on a risk-sensitive basis.

4. Risk assessment

We assess modern slavery risk by considering the nature of the service, the supplier's location, use of migrant or temporary labour, reliance on subcontracting, the complexity and transparency of the supply chain, and the degree of influence the Bank can exercise. Our professional, predominantly UK-based direct workforce presents a comparatively lower inherent risk, but no business or supply chain is risk free.

The supplier categories that may present a relatively higher exposure include labour-intensive facilities services, recruitment and temporary labour, construction or refurbishment activity, technology hardware supply chains, and outsourced services delivered through geographically extended or subcontracted arrangements. These categories should receive proportionate attention within supplier segmentation and due diligence.

5. Supplier due diligence and oversight

During the reporting period, the Bank used its supplier onboarding and third-party risk arrangements to assess new and material vendors. Relevant checks included the supplier's legal and regulatory standing, ownership and reputation, the nature and location of the services, and the controls appropriate to the risks identified. Higher-risk matters may be subject to additional information requests, enhanced review, contractual requirements, approval or escalation.

We recognise that our modern slavery-specific supplier framework remains developing. We are strengthening the consistency with which modern slavery risk is documented, segmented and monitored and will use the resulting information to prioritise further due diligence and engagement.

6. Training and awareness

During 2025, employees were supported by the Bank's wider training and awareness arrangements concerning ethical conduct, financial crime, whistleblowing and the escalation of concerns. The Bank has identified dedicated modern slavery training for colleagues involved in procurement, recruitment, supplier management and oversight as an area for further development.

7. Raising concerns and remediation

Employees are expected to raise suspected misconduct or exploitation through management, Compliance or the Bank's confidential whistleblowing arrangements. Relevant supplier contracts and relationships may also provide routes for escalation and investigation.

Where a concern is identified, the Bank will assess the available information, protect confidentiality, consider whether a notification to law enforcement or another authority is required, and determine proportionate steps to prevent further harm. Our response will take account of the interests and safety of affected workers. Ending a supplier relationship will not be treated as the only response where doing so could increase harm or impede appropriate remediation.

8. Measuring effectiveness

During the 2025 reporting period, modern slavery risk was monitored through the Bank's broader supplier, compliance, training and whistleblowing arrangements. The Bank did not maintain a separate consolidated modern slavery management information suite for that period. Establishing clearer, outcome-focused measures is therefore a priority for the next reporting cycle.

The Bank intends to monitor measures including:

• the proportion of relevant suppliers subject to documented modern slavery risk segmentation;

• completion of due diligence and enhanced review for suppliers assessed as higher risk;

• coverage of appropriate modern slavery provisions or supplier commitments in relevant contracts;

• completion of targeted training by relevant employees;

• concerns identified, assessed and resolved within agreed timescales; and

• actions completed and evidence of improvements arising from reviews, incidents or supplier engagement.

The number of concerns reported will not, in isolation, be treated as a measure of control effectiveness. Effective arrangements should support the identification, escalation and appropriate resolution of genuine concerns.

9. Priorities for 2026

During 2026, the Bank will continue to mature its approach by:

• Conducting a supplier risk segmentation exercise to identify and prioritise higher-risk suppliers.

• Expanding training modules to include specific case studies on modern slavery and human trafficking.

• Requiring suppliers in higher-risk categories to provide evidence of their own modern slavery statements or policies.

• Enhancing our third-party audit programme to include modern slavery compliance checks.

• Publishing progress against KPIs in our future statements to ensure transparency and accountability.

10. Board approval and signature

This statement was approved by the Board of Directors of LHV Bank Limited on 22 September 2026 and signed on its behalf of by:

Kris Brewster
Interim Chief Executive Officer and Director
LHV Bank Limited
Date: 23 September 2026