TRM Labs Modern Slavery Statement

Introduction

TRM Labs is a blockchain intelligence company that helps financial institutions, crypto businesses and government agencies detect and investigate crypto-related financial crime and fraud. Every day, we tackle challenges in data engineering, data science, and threat intelligence to advance our mission to build a safer financial system for billions of people.

We are committed to upholding the highest standards of professional business conduct, transparency and ethics. This statement outlines the steps we have taken and will continue to take to address the risk of modern slavery and human trafficking within our business operations and supply chains, pursuant to Section 54 of the UK Modern Slavery Act 2015 and the EU Directive on Corporate Sustainability Due Diligence.

This statement applies to TRM Labs, Inc. and its subsidiaries, including but not limited to TRM Labs UK Limited and TRM Labs Netherlands B.V., for the financial year ending December 31, 2025.

Organization structure and people

TRM Labs is headquartered in the United States and operates globally through a remote-first, distributed workforce located in select countries around the world. Given that the nature of TRM Labs business is digital technology, our personnel are generally skilled and educated workers. Prior to receiving an offer of employment, all prospective employees undergo an interview and comprehensive screening process. 

Our supply chains

Our supply chain includes the provision of IT and office equipment, procurement of various technology services as well as the procurement of  professional services from organizations that assist our business operations, such as law and accountancy firms. We work with suppliers and partners across select jurisdictions after following a careful vendor assessment process.

Policies in relation to slavery and human trafficking 

We have a zero-tolerance approach to modern slavery and human trafficking. Our commitment is reflected in the following policies and procedures:

• TRM Labs Employee Handbook: Our Employee Handbook reflects our commitment to acting ethically and with integrity in all our business relationships and outlines our expectations of ethical behavior from employees. 
• Vendor Procurement Processes: Our Procurement Processes ensure that TRM is assessing the types of vendors it interacts with and set expectations for suppliers to prevent modern slavery and comply with relevant laws.

• Whistleblowing Policy: Our Whistleblowing Policy provides employees, contractors, and suppliers with a mechanism to report concerns regarding unethical practices, including modern slavery.

Risk assessment and due diligence

TRM Labs considers the risk of slavery or human trafficking occurring in our own business or supply chain to be low. Nonetheless, we conduct risk assessments to identify areas within our operations and supply chain where the risk of modern slavery may arise and take active steps to mitigate these risks. Our due diligence processes include:

• Supplier Screening: Evaluating potential suppliers based on their adherence to ethical labor practices.
• Contractual Obligations: Incorporating appropriate compliance clauses into contracts with suppliers and partners.
• Audits: Conducting periodic audits and assessments of suppliers and partners, with a focus on high-risk sectors or geographies.

Key performance indicators to measure effectiveness of steps being taken

We are committed to continuous improvement in addressing modern slavery risks. To achieve this, we:

• Regularly review and update our policies and processes.
• Monitor developments in modern slavery legislation and best practices.
• Collaborate with industry partners and organizations to share insights and enhance our approach.