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Modern Slavery and Human Trafficking Statement

Our Company Structure

Curve OS Group Limited, incorporated in England and Wales, is the parent company for the Curve group of companies, which consists of:

  • Curve OS Holding Limited, Curve UK Limited (“CUK”) and Curve Credit Limited each incorporated in England and Wales;

  • Curve US, Inc., incorporated under the laws of Delaware;

  • Thackeray DAC, incorporated in Ireland;

  • Curve Europe UAB, incorporated under the laws of Lithuania; and

  • Curve Netherlands B.V., incorporated under the laws of the Netherlands.

(“Group”, “Curve”, “We”, “Us”, “Our”). 

CUK is the Group entity that has to publish a modern slavery statement under the Modern Slavery Act 2015. CUK is an e-money institution that is authorised and regulated by the Financial Conduct Authority (FCA). 

The other entities within the Group are not required to publish a modern slavery statement. However, as all entities are part of the Group and operate in a centralised governance framework, it means this statement covers actions related to the Group.

The Group is committed to upholding the highest standards of ethical conduct and integrity in all aspects of our operations. We recognize the grave issue of modern slavery and human trafficking and are committed to acting ethically and with integrity in all our business dealings and relationships.

Our Business

Curve’s wallet simplifies finances by uniting credit and debit cards, bank accounts, wallets, and loyalty programs into one personalised platform. Customers manage all their financial needs via a single app and Curve Card, usable online, offline, and on mobile. This empowers users to control their finances, save, optimise borrowing, and earn rewards, positioning Curve as the "Operating System for Money".

Our Supply Chain

At Curve, our supply chain comprises small enterprises (such as recruitment agencies, security services and marketing service providers) to large multinational companies mainly within the cloud computing and payment processing sectors, such as Google, AWS, Mastercard, Checkout, Nuvei and Thredd. The majority of our third-party partners are based in the UK, Europe, and the USA. Many of these entities have their own supply chains, indirectly linking Curve to a broader network of businesses and workers worldwide. 

Due to the nature of our business and the regions in which we operate (UK and EEA), the risk of modern slavery and human trafficking within our supply chain is considered low. See the Global Slavery Index for more information.

In cases where we deal with suppliers or partners in higher-risk regions, we mitigate potential risks through rigorous due diligence, including ensuring that we receive appropriate information on the third parties’ compliance with relevant modern slavery laws. We also endeavour to include our standard modern slavery clauses in contracts with relevant third parties.

Policies and Practices

To further mitigate the risk of modern slavery within our business, we have put in place the following policies:

  • Curve Group - Whistleblowing Policy

  • Curve Employee Handbook

  • Curve Group - Outsourcing and Third Party Policy

  • Curve Group - Modern Slavery Policy

Training and Awareness

We provide training to all Curve staff during their induction and on an annual basis (as required) to raise awareness of modern slavery risks and promote best practices for identifying and addressing them. Our goal is to ensure that everyone within our organisation understands the role they play in eradicating modern slavery.

Reporting and Accountability

We maintain clear reporting mechanisms to enable employees, suppliers, or any other party to voice concerns regarding potential modern slavery practices. All reports are taken seriously and investigated promptly, with appropriate corrective actions implemented as needed.

Looking Forward

We are committed to continually improving our efforts to combat modern slavery and human trafficking. This includes refining our policies, enhancing supplier engagement, and staying informed about best practices and emerging risks.

We will also be monitoring certain metrics (such as % of colleagues who completed their modern slavery training and number of reports raised as part of the Modern Slavery Policy) to help us understand if our approach is working and to spot any improvement opportunities.

Board Approval

This statement was approved by the Board of Directors of Curve OS Group Limited on 17 January 2025 and is made pursuant to section 54(1) of the Modern Slavery Act 2015 and reflects our commitment to addressing and preventing modern slavery for the financial year ending 2023.