Affirm U.K. Limited's Modern Slavery and Human Trafficking Statement

This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Affirm U.K. Limited ("Affirm U.K.") during the year ended 31 December 2022, to prevent modern slavery and human trafficking in our business and supply chains within its business or by its suppliers.

Affirm U.K. is fully committed to ensuring that our business and supply chains are not involved in modern slavery or human trafficking. The term "modern slavery" is used to describe situations where a person is deprived of their liberty in order to exploit them for personal or commercial gain. It is a criminal offence, a violation of fundamental human rights, and can take a number of forms, including: slavery, forced or compulsory labour, servitude, human trafficking, and trafficking for prostitution or sexual exploitation. Affirm U.K. takes a zero-tolerance approach to modern slavery and will not knowingly support or deal with any business or supplier involved in such practices.

This statement applies to Affirm U.K. including its parent company Affirm, Inc.

It is Affirm U.K.'s policy that we will not support or deal with any business knowingly involved in modern slavery or human trafficking.

About Affirm

Affirm is committed to conducting its business in an ethical and environmentally responsible manner. Affirm, Inc. is headquartered in the United States. Affirm U.K. is locally based in London, United Kingdom. Affirm U.K. is currently not subject to the authority of the Financial Conduct Authority.

Affirm U.K. sees the identification and mitigation of modern slavery risks in supply chains as requiring ongoing attention and improvement and is committed to addressing this issue through strong policies, training & education, and robust independent oversight.

Whistleblowing

Our Global Whistleblowing Policy encourages all our employees to play a key role in preventing and detecting wrongdoings and to express any concerns regarding any misconduct relating to our business.

Employees are encouraged to raise their concerns about any suspected or known criminal conduct or any type of misconduct taking place through Affirm, our customers or third parties. Employees can raise disclosures anonymously and confidentially through our Whistleblowing channel.

Our Commitment To Modern Slavery Act

Affirm is committed to the principles and provisions of the Modern Slavery Act. Affirm at all times will ensure it conducts its business in compliance with all legislation and regulations, which are relevant to its business within the countries that it operates. We do not enter into business with any organisation, which knowingly supports, or is found to be involved in slavery, servitude or forced or compulsory labour.

As an equal opportunities employer, we are also committed to creating and ensuring a non-discriminatory and respectful working environment for our people. Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the U.K.

Our Policies

In 2022, Affirm reviewed internal policies, instructions, and governance demonstrating Affirm's commitment to identifying and mitigating modern slavery, requiring employees to raise concerns in relation to any identified or suspected non-compliance, and confirming that employees will not suffer any detriment for raising such concerns. Affirm continuously reviews and updates all its policies, instructions and governance.

Our Conduct Policy has been signed off at director level, which applies to all employees across Affirm, to reflect our commitment to conduct all our business in an honest and ethical manner.

These internal policies, instructions and governance include, but are not limited to, the following:

• The Code of Ethics and Business Conduct

• The Anti-Bribery and Anti-Corruption Policy

• The Financial Crime Global Anti-Bribery and Corruption Policy

• The Whistleblower Policy

• The Policy Against Discrimination, Harassment and Retaliation

Our Business and Supply Chain

In acknowledging the aims and abiding by the provisions of the Modern Slavery Act, Affirm maintains effective systems and controls to ensure that its supply chains are transparent and free from modern slavery.

The majority of Affirm financial products and services are technology related and created with the assistance of suppliers throughout the U.S., Australia, Canada, Spain, Poland, and the U.K., and Affirm's highly-skilled employees. As a result of using regional suppliers and primarily a local workforce, Affirm faces minimal risk of modern slavery. Notwithstanding this, Affirm's Enterprise Risk Management team adheres to internal policies, manuals, and processes to ensure Affirm selects suppliers holding the same high business standards and core values as it does. Key internal policies, manuals and processes include, but are not limited to, the following:

• Third Party Risk Management Policy

• Due Diligence Form Completion

Affirm's supply chains are made up of the following:

• IT service and communications including customer support activities

• IT hardware and software, including licenses and open source software

• Data storage services

• Financial institutions

• Professional services from our advisors including our lawyers, auditors and accountants

Third-Party Due Diligence

We aim to build relationships with our merchants and suppliers to ensure that they are aware of our commitment to protect human rights and the environment, and ensure they are aware Affirm has a zero tolerance to slavery and human trafficking. As part of our processes, we require all of our suppliers to comply with the requirements of the Modern Slavery Act.

Affirm deals with third parties for the provision of a range of products and services. It is Affirm's intention to only contract with third parties who satisfy our internal high standards with regards to employment and welfare conditions. In order to help identify and monitor the risk of slavery and human trafficking in our supply chain we conduct pre-contracting due diligence and ongoing due diligence on third parties, taking into account the following risk factors:

• The Country and jurisdiction that the third-party operates in (including where they have supply chains in)

• The sector and industry the third-party operates in; and

• The services and products produced, manufactured or supplied by the third-party.

Where a third party or outsourcing provider uses another party (i.e. a fourth party), to provide the agreed services to Affirm, this is considered to be a subcontracting agreement.

When subcontracting agreements are in place, Affirm actively works to adopt appropriate contractual clauses that obligate the third party or outsourcing provider to conduct an appropriate level of oversight on the subcontracted services and provide information as may be required to evidence subcontractors are meeting the relevant regulatory obligations.

Contractual Obligations

We will actively work to include our own standard modern slavery clauses in our contracts with relevant suppliers. These clauses seek to manage modern slavery risks and ensure that we receive appropriate information on suppliers' supply chains and organisations, including copies of their modern slavery statements if they are required to report under the UK Modern Slavery Act.

Our suppliers have a contractual obligation to ensure compliance with all applicable laws that apply to their supply of goods and services to Affirm, regardless of the jurisdiction in which they operate. This includes the UK Modern Slavery Act and any local legislation that is aimed at combating modern slavery.

Risk Assessment

During 2022 we will continue to assess our business and supply chains to identify any particular sectors or geographies where a greater risk of modern slavery or human trafficking may occur and have sought to identify what measures are in place to mitigate those risks.

Duty To Report

Affirm employees are responsible for detecting, reporting, and preventing modern slavery from occurring within its business and supply chains. Any and all concerns or suspicions that modern slavery may be present in any part of the business or in supply chains should be reported at the earliest possible stage to Affirm's reporting hotline AffirmEthics.com either identifiably or anonymously, by web, SMS, or phone. Employees, contractors, and third parties may use this hotline. Affirm has a strict non-retaliation policy, meaning employees will not be disciplined for reporting a suspected violation in good faith or participating in an investigation related to or opposing any potential violations of the Modern Slavery Act.

This statement was approved by the Board of Directors of Affirm U.K. on 25/10/2022 is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes Affirm's slavery and human trafficking statement for the year ending 31 December 2022. This statement was signed by the Board of Directors of Affirm U.K. on 25/10/2022.

Dated: 25/10/2022

By: Katherine Adkins

Katherine Adkins (25 October, 2022 14:21 PDT)

Katherine E. Adkins, Chief Legal Officer, Affirm Inc.