Modern Slavery and Human Trafficking Statement

1. Introduction and commitment

Ronghan International Limited (the “Company” or ‘‘Onerway’’) is a UK-based, Financial Conduct Authority (FCA)-regulated Electronic Money Institution providing authorised payment/e-money services, including merchant acquiring and payout services. The Company recognises that modern slavery, forced labour, servitude and human trafficking are serious abuses of human rights and may arise in business operations, third-party supply chains or the activities of merchants using financial services.

We are committed to lawful and ethical conduct, appropriate safeguarding of workers, and a risk-based approach to identifying and responding to relevant exploitation risks. This statement describes our approach, subject to the factual verification points identified in the review note below.

2. Statutory position and scope

Section 54 of the Modern Slavery Act 2015 requires qualifying commercial organisations carrying on business in the UK, supplying goods or services, and having annual turnover of at least £36 million (including relevant subsidiary turnover) to publish an annual modern slavery statement. FCA authorisation as an EMI does not itself create a separate obligation to publish a statement under that section.

Where the Company is below the threshold, this document may be issued voluntarily in response to commercial due-diligence requests and does not imply that the Company is legally required to publish a Section 54 statement.

3. Business activities and risk exposure

As an EMI operating in payment services, the Company considers relevant exposure across three distinct areas:

• Our workforce and operations: recruitment, employment practices, contractors, outsourced staff, and the treatment of workers.
• Third-party suppliers: technology, cloud hosting, customer support, facilities, recruitment agencies and other outsourced or intra-group service providers, including cross-border arrangements where relevant.
• Merchant and payment activity: the possibility that customers or their counterparties operate in sectors or jurisdictions associated with labour exploitation, or that financial services are used to facilitate proceeds linked to exploitation.

Payment processing volume, geographic reach or merchant sector alone does not establish modern slavery; potential risk indicators are assessed in context rather than treated as proof of wrongdoing.

4. Governance and accountability

The Board retains ultimate oversight of the Company’s approach to ethical business conduct and material risks. Subject to the Company’s approved governance arrangements, Compliance/Financial Crime may coordinate relevant risk assessments, escalation, monitoring and reporting, while HR and supplier owners manage controls within their areas. Material concerns should be escalated to designated senior management promptly and documented.

5. Preventative and detective controls

5.1 Staff and recruitment

Appropriate measures may include identity and right-to-work checks, proportionate screening, transparent employment terms, reputable recruitment channels, access to a confidential concerns process, and prohibition of coercive recruitment practices. The Company should only describe any particular measure as implemented once confirmed by HR and the relevant policy owner.

5.2 Supplier and outsourcing oversight

The Company applies or proposes to apply proportionate supplier due diligence informed by service criticality, location, industry and use of subcontractors. Possible checks include supplier identity, ownership, reputational concerns, contractual ethical standards, periodic reassessment and escalation where information indicates heightened risk. Outsourcing and third-party oversight should align with the Company’s actual FCA regulatory obligations and internal framework.

5.3 Merchant onboarding and ongoing monitoring

For an EMI providing merchant acquiring services, modern slavery risk is relevant to merchant acceptance and ongoing financial-crime oversight. Risk-based merchant due diligence may consider the merchant’s business model, beneficial ownership, operating jurisdictions, goods and services, use of labour-intensive supply chains, unusual payment patterns, adverse media and links to higher-risk sectors. Enhanced due diligence and management approval may be warranted where red flags cannot be resolved through ordinary checks.

Transaction monitoring and ongoing reviews may identify unexplained payment flows or other indicators that warrant financial-crime investigation. Any suspicion should be assessed by the responsible financial-crime team/MLRO under applicable reporting requirements. Merchant restriction or termination decisions must follow contractual terms, applicable law and documented governance.

6. Training, speaking up and responding to concerns

Staff in relevant roles should be made aware of indicators of exploitation, the appropriate internal escalation route and the importance of accurate records. Workers and third parties should have an accessible channel to raise concerns without retaliation, where the Company’s arrangements provide for this. Potential incidents should be considered for safeguarding, regulatory, law-enforcement and suspicious-activity reporting as appropriate; the Company should not automatically disclose sensitive case information to commercial counterparties.

7. Oversight and continuous improvement

The Company aims to periodically evaluate the adequacy of its approach through proportionate management information, such as completion of relevant staff training, status of higher-risk supplier or merchant reviews, issues escalated, remedial actions and policy review dates.

8. Approval and publication

This document covers the reporting period identified above. Where the Company is subject to Section 54, the statement must be approved by the Board and signed by a director, and published on the Company’s website with a prominent homepage link. For a voluntary statement, the Company may adopt an equivalent internal approval process for good governance.