ESG positioning &
Modern Slavery Statement

Making a positive impact, without compromise

At Zodia Custody, we are committed to minimising our environmental impact and promoting sustainable business practices. As a custodian of digital assets, our direct emissions are relatively low and we do not consider ourselves to be more resource-intensive than other global technology companies.

We aim to drive sustainability by:

• Supporting cross industry initiatives such as TechZero and the Crypto Climate Accord
• Supporting initiatives developing green mining solutions;
• Maintaining ethical standards, including robust anti-bribery and corruption policies;
• Engaging constructively with regulators; and
• Investing in employee training, development and wellbeing.

Consensus mechanisms

Whilst Zodia Custody does not issue any digital assets, we recognise our obligation as a crypto asset service provider to disclose information related to the principal adverse impacts of the consensus mechanisms used for the crypto assets that we custody.

The following paragraphs outline key information relating to the consensus mechanisms for major crypto assets in our custody, such as BTC and ETH.

Proof of Work

Proof of Work mechanisms such as those used by Bitcoin and Litecoin are associated with a high climate impact, driven by the solving of cryptographic puzzles to validate transactions and mint new coins, which is energy-intensive and results in the production of waste and emissions of greenhouse gases.

Proof of Stake

Proof of Stake mechanisms such as those used by Ethereum, Solana and Cardano are associated with a relatively low climate impact as no computational mining is involved.

Note that Layer 2 networks typically carry very similar climate impact profiles as the Layer 1 upon which they are based.

Zodia Custody is committed to upholding the highest ethical standards in our business practices and preventing modern slavery and human trafficking in our operations and supply chains.

Our business and risk assessment

As a crypto custodian, Zodia Custody primarily deals with digital assets and technology. While we don’t have traditional physical supply chains associated with a high risk of modern slavery, we recognise the potential for risks in certain areas:

• Third-Party Providers: We rely on various third-party vendors for services such as software development, cloud storage, and security solutions.
• Recruitment Practices: We are committed to ethical recruitment practices within our own company.

Our actions to prevent Modern Slavery

• Vendor Due Diligence: We conduct thorough due diligence on all potential third-party vendors, including assessing their modern slavery policies and practices.
• Contractual Clauses: Our contracts with third-party vendors include clauses prohibiting modern slavery and human trafficking in their operations.
• Employees: We provide our employees with an employee handbook and ongoing training on modern slavery and human trafficking awareness, equipping them to identify and report potential issues.
• Reporting Mechanisms: We have established clear reporting channels for employees to raise concerns about potential modern slavery risks.
• Policies and Continuous Improvement: We regularly review and update our modern slavery policies and procedures to reflect best practices and emerging risks.

We are committed to transparency and will continue to assess and mitigate the risk of modern slavery in our operations and supply chains. We encourage our stakeholders to report any potential or suspected violations of our modern slavery policy.

This statement is made voluntarily in accordance with section 54 of the UK Modern Slavery Act 2015.