Modern Slavery Statement

1. Introduction

Friam Limited (“we”, “us”, “our”) is the company behind AgentGuard, Ready Vet Staff (VetGuard), HotelGuard, FirmGuard, CareGuard and the EveryGuard family of UK compliance products. We are committed to preventing modern slavery and human trafficking in all its forms. We believe that ethical business practices are fundamental to our operations, regardless of legal requirements.

This statement sets out the steps we take to ensure that slavery and human trafficking are not taking place in our business or supply chains.

2. Our business

AgentGuard is a software-as-a-service compliance platform for UK estate and letting agents. We:

• Scan agent websites for compliance disclosure gaps
• Draft and host agents’ AML and consumer-protection policies
• Deliver AML training to agent firm principals and their teams
• Run customer due-diligence and sanctions / PEP screening on the agent’s instruction
• Operate solely within the United Kingdom

3. Our commitment

We are committed to:

• Acting ethically and with integrity in all our business relationships
• Ensuring that modern slavery does not occur in any part of our business
• Treating all team members, contractors, and customers with dignity and respect
• Building product features that surface, rather than obscure, the regulated character of high-risk transactions
• Reporting suspected human-trafficking or modern-slavery indicators surfaced through our customer-verify or sanctions-screening flow to the appropriate authorities, in line with our obligations

4. Our policies

4.1 Fair employment

• All Friam team members are paid at or above the Real Living Wage
• We verify right to work in the UK through legitimate processes only
• We do not retain any team member’s identity documents
• We pay invoices to our contractors and freelancers within 14 days

4.2 Customer-verify and sanctions screening

Our customer-verify flow exists in part because identity verification is one of the screens that modern-slavery and human-trafficking indicators sometimes appear at. When operators flag a concern that could indicate trafficking, our SAR-readiness workflow guides the firm’s MLRO to file with the National Crime Agency.

4.3 Transparency

• We publish our governance documents (including this one) publicly on the marketing site
• We publish our subscribers’ AML compliance status as a public Trust page so consumers can verify firm credentials before transacting
• We maintain open communication channels for concerns

5. Supply chain

Our supply chain is limited and primarily consists of:

• Cloud infrastructure providers (Amazon Web Services)
• Communication providers (Resend, Twilio)
• AI sub-processor (Anthropic)
• Payment processor (Stripe)
• Professional services (legal, accounting)

We select suppliers who share our commitment to ethical practices and, where appropriate, require confirmation of their own modern-slavery policies.

6. Risk assessment

We have assessed the risks of modern slavery in our operations:

• Direct operations: low risk — small, UK-based team paid above the Real Living Wage, transparent employment practices, no manual labour or supply-chain manufacturing
• Supply chain: low risk — primarily UK-based and large publicly-listed technology providers with their own modern-slavery statements
• Customer transactions: indirect — the property and rental sector intersects with trafficking risk in known high-risk patterns (cash transactions, PEP-adjacent purchasers, unverified-source-of-funds rentals); our product is designed to surface these

7. Training and awareness

All team members are made aware of:

• The indicators of modern slavery and human trafficking
• The intersection between AML obligations and trafficking detection
• How to report concerns or suspicions
• The importance of treating all customers and end-customers with dignity

8. Reporting concerns

We encourage anyone with concerns about modern slavery in our business or supply chain to report them. Reports can be made:

• By email to: legal@everyguard.uk
• Through the Modern Slavery Helpline: 08000 121 700

All reports will be investigated thoroughly and handled confidentially.

9. Review

This statement is reviewed annually. We will continue to assess our practices and strengthen our approach as our business grows.

10. Approval

This statement has been approved by the directors of Friam Limited and will be reviewed and updated annually.

Friam Limited
Company No. 14219476
May 2026