Privacy Policy

Modern Slavery Act Statement

Introduction

This statement is made pursuant to section 54 of the UK Modern Slavery Act 2015 and sets forth the steps that First Mile Group, Inc. has taken during the last financial year to ensure modern slavery and human trafficking is not taking place in any parts of its business or in any of its supply chains. This statement covers the steps taken by First Mile Group, Inc. and all of its group subsidiaries, including Alloy Inc Limited (collectively, "Alloy" and “our”).

Our organization

Alloy provides an end-to-end identity and fraud prevention platform that helps financial institutions and fintechs automate and manage decisions related to onboarding, ongoing fraud and anti-money laundering (AML) monitoring, and credit underwriting. Alloy is headquartered in New York, NY and has over 300 team members across its offices in the United States and United Kingdom.

Our supply chains

As a technology company, Alloy’s supply chain primarily consists of cloud infrastructure providers, software vendors and technology partners, and professional services providers (e.g., legal, accounting, recruiting). Alloy also engages independent contractors and third-party service providers, some of whom may be located outside the United States and the United Kingdom. In accordance with our written policies, Alloy enforces onboarding, ongoing oversight, and contracting requirements with respect to vendors. Alloy’s relationship with a vendor may be adjusted or terminated in the event that the monitoring reveals deficiencies or material risks that are unacceptable to Alloy. This would include any identified risk of modern slavery or human trafficking. We have not identified any potential modern slavery or human trafficking issues to date in our supply chains.

Policies and controls

Alloy maintains policies and procedures that support ethical business practices and help mitigate the risk of modern slavery and human trafficking. These include an employee handbook, which serves as a code of conduct and sets expectations for ethical behavior, as well as guidelines and processes for reporting concerns, including whistleblower protections. These policies are intended to promote lawful and ethical conduct across Alloy’s operations.

Risk assessment

Alloy is not aware of any slavery or human trafficking issues within its group businesses or supply chains. In the last financial year, no potential issues of this type have been identified or reported through internal reporting channels, other whistleblowing channels, or otherwise.  Reflecting upon the position as set out above, we consider the risk of slavery or human trafficking in Alloy, and its supply chain continues to be low. However, should any potential issue be identified, Alloy will act swiftly to investigate and, where necessary, act to ensure there is no modern slavery or human trafficking occurring in its business or supply chains.

Approval

This statement was approved by the board of directors of First Mile Group, Inc. on June 25, 2026.

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