Western Union’s

Modern Slavery and

Human Trafficking
Statement for 2022

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 Reporting Entities
This Modern Slavery and Human Trafficking Statement
(“Statement”) is made by The Western Union Company
(the “Company”) pursuant to the Australian Commonwealth
Modern Slavery Act 2018 and section 54(1) of the UK
Modern Slavery Act 2015 on behalf of the Company’s
affiliates conducting business in Australia and the UK. This
Statement is for the financial year ended December 31, 2022
and applies to and has been approved by the boards of the
Company entities below.

Company Company Number

Western Union Financial Services 082282773

(Australia) Pty Ltd

Western Union Retail Services 2383761

GB Limited

Western Union GB Limited 4129906

Western Union Payment Services 11326797

GB Limited

Western Union International FN256184t

Bank GmbH

Western Union Payment Services 471360

Ireland Limited

Our current Statement and those for previous financial years

can be found at the link below.
https://ir.westernunion.com/investor-relations/corporate-
governance/governance-documents/default.aspx

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3
 Our Business,
Structure, and
Supply Chains

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 Western Union is a leader in global money movement and payment services, providing
people and businesses with fast, reliable, and convenient ways to send money and make
payments around the world. Today, we have a market leading retail and digital footprint,
offering services in more than 200 countries and territories and employing approximately
8,900 employees born in more than 100 countries.

Our business consists of two primary segments.

Consumer-to-Consumer Segment
Money transfers from one consumer to another are the core of our business, representing
approximately 89% of total consolidated revenues for 2022. A substantial majority of
these transfers were cross-border transactions. Our money transfer service is mainly
conducted through our retail agent locations worldwide but also includes our money
transfer transactions conducted and funded through websites and mobile applications
marketed under our brands. This segment includes five geographic regions whose
functions are primarily related to generating, managing, and maintaining agent
relationships and localized marketing activities. By means of common processes
and systems, these regions create one interconnected global network for consumer
transactions.

Business Solutions
Our Business Solutions segment facilitates payment and foreign exchange solutions,
primarily cross-border, cross-currency transactions for small and medium size enterprises
and other organizations and individuals. The majority of the segment’s business relates
to exchanges of currency at spot rates, which enable customers to make cross-currency
payments. In addition, in certain countries, we write foreign currency forward and option
contracts for customers to facilitate future payments. On August 4, 2021, we entered into
an agreement to sell our Business Solutions business to a third-party purchaser. The sale
will be completed in three closings, with the first and second closings occurring on March
1, 2022 and December 31, 2022, respectively. The third closing is expected in the third
quarter of 2023.

Our vision is to be the world leader of branded payments and accessible consumer
financial services, serving the aspiring populations of the world. In October 2022, Western
Union unveiled its Evolve 2025 strategy, which focuses on creating a customer-centric
business and providing essential financial services beyond money transfer. Evolve 2025
has four strategic pillars.

• Position our retail business as the gateway to Western Union

• Accelerate the growth of our digital business
• Drive customer experience and operational excellence
• Deliver accessible financial services

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 Services in more Real-time Hundreds of thousands
than 200 countries account payout of locations in urban,
and territories in 100 countries rural, and remote areas.

Payout in 90%+ Global Customer

nearly 130 consumer brand service in 40
currencies awareness1 languages

To conduct our services and to meet our commitments to our customers and
stakeholders, Western Union sources from suppliers around the world. As of
December 2022, our active vendor base consisted of thousands of companies.

They provide a diverse range of goods and services, including cloud-based software
services, software application support, the development, hosting and maintenance of
our operating systems, merchant acquiring services, call center services, and other
operating activities.

1
As of Q1 2021

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 Our Policies
and Approach

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 Consumer trust depends on cross-border money movement that is safe, secure, and built
on a foundation of integrity. We work with customers, regulators, and partners to uphold the
integrity of our financial infrastructure. Our partnerships with law enforcement agencies,
multilateral and private organizations, and nonprofits help combat illicit activity and prevent
fraud. Through our core values of trust and respect, we aim to:

• Avoid causing or contributing to negative human rights impacts.

• Prevent or mitigate abuses that occur in our operations and through those of our
business partners.
• Promote human rights by contributing to the global communities we serve.

Aligned with the requirements under the Commonwealth Modern Slavery Act 2018 and the
UK Modern Slavery Act 2015, we condemn modern slavery and human trafficking. We do not
use forced or involuntary labor and prohibit this in any part of our business or supply chains.
We expect our suppliers and those involved in procurement processes for the Company
to comply with these values. We are committed to acting ethically, demonstrating high
professional standards, and complying with applicable laws and regulations. We expect the
same high standards from those with whom we do business.

We recognize that the risks posed by modern slavery and human trafficking are constantly
evolving, and so, too, must our efforts to combat it. Through our Anti-Human Trafficking
Initiative, the Company detects, deters, and reports human trafficking issues. This includes
educating Western Union’s global network of agents, its employees, and its partners about
human trafficking and other forms of modern slavery. It also includes participating in
external working groups, listed in more detail below, and working with law enforcement
agencies and nonprofit entities. This collaboration plays an important part in helping us to
remain actively engaged in evaluating the changing nature of modern slavery and human
trafficking and adapting our approach to respond to prevailing threats.

This year, for the second consecutive year, Ethisphere, a global leader in defining and
advancing the standards of ethical business practices, recognized Western Union as a
2023 World’s Most Ethical Companies Honoree®. Western Union was one of only 135
organizations recognized, and one of seven honorees in the financial services industry.

Related Policies
Western Union’s commitment to enforcing ethical business practices, including the
detection and prevention of slavery and human trafficking, is embedded in our policies and
procedures. Our Code of Conduct serves as a guidepost for how we treat our employees,
customers, business partners, and other stakeholders. Our employees confirm they have
read and will comply with our Code of Conduct, which not only condemns human rights
abuses and prohibits the use of forced or involuntary labor, but also defines our employees’
responsibility to speak up when they believe there to be possible violations of policies or law.

Our Vendor Code of Conduct sets out our expectations for vendors, suppliers, and others
acting on Western Union’s behalf, including guidelines regarding child labor, slavery, human
trafficking, and other labor standards.

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 Our anti-money laundering program includes our global Anti-Money Laundering and
Combating the Financing of Terrorism policies that set forth the principles for preventing
Western Union’s services from being used for illicit purposes. We also have policies that
establish due diligence requirements for clients, agents, and partners, designed to detect
and mitigate concerns of modern slavery and/or human trafficking. We conduct enhanced
due diligence periodically to identify illicit activity over the lifespan of the business
relationship with Western Union.

Our Code of Ethics for Senior Financial Officers provides principles of ethical conduct to
which each senior financial officer of the company is expected to adhere. This includes a
commitment to promoting ethical behavior as a responsible partner among peers in the
work environment and community.

Our vendor risk policies establish requirements to ensure we conduct appropriate risk
assessments of potential vendors prior to engagement to ensure we engage quality and
trustworthy vendors.

Our global sourcing and procurement policies govern the acquisition of products and
services worldwide and addresses ethical purchasing and risk mitigation, including risk
related to human trafficking and modern slavery.

Our Human Rights Statement explains our approach to respecting and promoting
human rights. It is guided by internationally recognized standards, such as the Universal
Declaration of Human Rights, the International Labour Organization’s Declaration on
Fundamental Principles and Rights at Work, and the UN Guiding Principles on Business
and Human Rights.

Ethics Helpline
Our primary channel for reporting issues related to modern slavery and human trafficking
is the Company’s Ethics Helpline. It is a secure and confidential mechanism for receiving
and processing whistleblower reports and other concerns. The Ethics Helpline allows
employees and other reporters to raise concerns anonymously, subject to applicable
law. Reports involving suspected human trafficking incidents can be made by visiting the
Helpline internet site at westernunionhelpline.com or by phone. Both avenues for reporting
concerns are typically available 24 hours a day.

The web-based reporting tool is available to individuals in six languages while the toll-free
phone line supports calls in over 150 languages. The Ethics Helpline is administered by an
external, independent, third-party vendor, and concerns reported through the Helpline are
forwarded to the Western Union Ethics Office for review. Western Union reviews concerns
raised and investigates and takes action, as appropriate. Western Union prohibits
retaliation for raising concerns in good faith.

In 2022, Western Union did not receive complaints through the Helpline involving
suspected human trafficking incidents.

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 Assessing and
Managing Risk

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 In 2020, with the support of an external expert, our Company conducted an assessment
that helped us identify and prioritize the negative human rights impacts that are most
likely to arise in connection with our business and our business partners and develop
mitigation and remediation strategies to address the impacts we identified. Informed
by the UN Guiding Principles on Business and Human Rights and other internationally
recognized standards, the assessment included:

Desktop research analyzing Company publicly available

information and reports by NGOs and other stakeholders.

A review of internal documents, processes, and procedures

Western Union leverages to identify and manage human rights risk.

Interviews with internal and external stakeholders.

One of the main potential impacts we identified was the wrongful use of our network
by illicit actors to facilitate human trafficking and other human rights abuses that harm
individuals and communities. Human traffickers can and do attempt to use platforms
like Western Union’s to recruit potential victims of human trafficking, finance the lodging
and transportation of victims, and control victims. We recognize some of these risks are
inherent to our role as a money movement and payments service provider, and some are
due to external, contextual factors in the geographies where we operate, such as conflict,
weak rule of law, and the uneven application of the law.

Our leading compliance program, explained in more detail below, helps manage these
risks. We are committed to integrating additional lessons learned from the assessment to
continuously improve our approach to combating human trafficking and modern slavery.

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 Steps We Took in
2022 to Address
Modern Slavery
We take a multi-faceted approach to prevent
our services from being used to facilitate
illicit money movement associated with
modern slavery and human trafficking. This
includes utilizing a highly developed set of
controls to monitor and analyze transactions;
educating our agents, employees, and
partners about human trafficking and other
forms of modern slavery; and partnering with
external organizations.

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 Compliance Program
The bedrock of our efforts in combating modern slavery is our leading compliance
program. Our comprehensive global policies and procedures establish the framework
for our compliance program, based on international standards created by organizations
such as the Financial Action Task Force. In line with legal and regulatory requirements, our
approach is risk-based.

We continue to maintain an AML Risk Assessment Framework to detect, deter, prevent,

and report illicit transactions with dedicated teams of employees who are responsible for
risk assessment, risk modeling, and ongoing analysis. This framework requires a multi-
faceted approach to assessing and managing risk, including, but not limited to, analysis
such as:

• Consumer-level monitoring, investigation, and reporting

• Agent-level due diligence, monitoring, investigation, and oversight
• Product risk assessment
• Country and regional level risk assessments
• Emerging risk and strategic intelligence analysis
• Control testing and audits

Our compliance program is designed to manage complexity across geographies.

Transactions between specific countries and cities pose varying risks. We manage
nuanced transaction risks across thousands of geographic connections. For example, we
might treat a transaction from Madrid to Marrakesh differently than one from Barcelona
to Casablanca. Although they are both Spain to Morocco, the risks of transactions
between these locales may differ depending on a variety of factors, including the specific
cities involved, the amount of the transfer, other behaviors associated with the involved
consumers, and the type of product.

When transaction activity associated with human trafficking features targetable patterns
that are relatively diagnostic of this crime type, we build controls to proactively prevent
our systems from similar abuse. We have developed and implemented numerous controls
and alerts designed to specifically target patterns and geographies that are higher risk for
links to human trafficking. We screen our transactions, as well as the data associated with
our customers, clients, partners, and agents, against a range of government sanctions
and other internal and external watch lists. We do this to identify prohibited parties and
potentially illicit activity and may freeze or reject funds and transactions where required.
Our transaction screening takes place while the money is moving and allows for the real-
time collection of data to separate false positives from true matches. We also monitor
transactions handled through our platform. Our systems are designed to detect potentially
suspicious activity and block prohibited users and illicit activity.

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 We continue to make significant compliance-related investments in people, processes,
and technology, including state-of-the-art systems, predictive analytics, machine
learning, artificial intelligence, and potential fraud victim interviews. Our Real Time Risk
Assessment engine analyzes threats, makes decisions, and takes action in milliseconds
to prevent parties that meet specified parameters from completing transactions.
We demonstrate our ongoing commitment through the transactions we process and
partnerships we form.

Employee Training
We trained our employees on ethical conduct and reporting misconduct in our annual
online Code of Conduct training, which included a module dedicated to human trafficking.
The training also required employees to certify having read and understood the Code
of Conduct, which prohibits the use of forced or involuntary labor. We also require our
employees to complete compliance training at least annually, covering anti-money
laundering, fraud prevention, anti-corruption, and other areas. Ongoing targeted training
also provides topic-specific education based on factors such as geography or employee
job function.

Additionally, our Financial Intelligence Unit (FIU) staff – comprised primarily of

Investigators, Analysts, and Outreach personnel – both facilitate and undergo regular,
advanced training on the human trafficking typology. Staff present at and attend external
webinars and other training events and collect, collate, and raise awareness around
relevant trend information obtained from law enforcement, NGO partners, and open
sources.

The FIU annually refreshes a variety of reference materials that contain human trafficking-
specific trends, investigative resources, and specific transaction patterns designed to
advance investigations and understanding of the changing human trafficking landscape.

Third Party Due Diligence

We know it is important to do business with the right people for the right reasons and are
committed to complying with applicable laws, including applicable economic and trade
sanctions designed to support national and international security, policy, and human
rights interests. Concerns related to human-trafficking are among the criteria that these
sanctions programs use to impose sanctions on individuals or entities.

We also implement due diligence procedures to vet our agents and other business
partners and take seriously our obligations to implement Know Your Agent (KYA) and
Know Your Customer (KYC) requirements. Under these processes, we collect and verify
identifying information to make sure we know with whom we are conducting business.
This information helps us identify sanctioned parties and others with whom we are
prohibited from doing business and allows us to identify risk indicators and prevent
transactions when necessary. Our due diligence and KYA and KYC programs, moreover,
are informed by ongoing information monitoring efforts, through which new information
may come to light.

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 Vendor Relations
Western Union maintains a Vendor Risk Oversight program to formalize how we review
potential new vendors for risk. We take a risk-based approach to assess vendors for
potential human trafficking or modern slavery within their business. We conduct due
diligence before we enter into third party contracts to identify potential risks and mitigate
risks as appropriate. For example, we identify vendors in high-risk jurisdictions as well as
vendors that provide high-risk services and mitigate these risks through actions such as
contractual terms.

The Vendor Risk Committee is responsible for developing and monitoring our Vendor
Risk Oversight program. The program aligns with our strategic priorities and vendor risk
management objectives and is continually enhanced. The Committee is made up of senior
leaders from across the organization and met throughout 2022.

In accordance with our policies, prior to working with Western Union prospective vendors
must complete our risk assessment process, which includes completion of a survey that
is analyzed by applicable departments within Western Union who consider risks related
to human trafficking and modern slavery. Western Union’s contractual documentation and
standard terms and conditions require third parties and their workers to comply with all
applicable laws and regulations, including all applicable laws and regulations prohibiting
human trafficking and modern slavery.
Agent Training and Oversight
Because many of our transactions are initiated or completed by third-party agents, it is
particularly important to us that these partners do their part to ensure compliance with
applicable laws and regulations. In addition to conducting due diligence on our agents, we
conduct risk-based reviews of their compliance programs. These reviews help us ensure
that our agents comply with our requirements as well as laws and regulations on anti-
money laundering and combating the financing of terrorism.

Western Union also trains our new agents to detect, prevent, and report numerous
forms of suspicious activity—including activity potentially related to human trafficking
and modern slavery—to Western Union and/or the appropriate regulatory agencies.
All new agents must identify a compliance officer who must complete compliance
program training before providing our services to consumers. Annually, agents must train
employees across their network on our compliance program. We give our agents kits,
newsletters, alerts, and an online Agent Resource Center as resources to help combat
illicit activity. For example, in July 2022, we issued a global newsletter to network and
master agents with a specific focus on human trafficking.

In 2020, we set a goal to conduct more than 300,000 engagements—such as compliance

program reviews and trainings—by 2025 with partners who offer Western Union services.
Each compliance review and training is an opportunity to build capacity within the financial
system to detect and prevent illicit activity. These engagements also directly support key
business outcomes, such as reducing misuse of our services and fraud rates. We met this
goal in 2021. In 2022, we continued assessing ways to make an impact in this area.

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 In addition to providing general human trafficking awareness content available in agent
compliance program manuals, job aids, newsletters, and online training, Western Union
also provides targeted training on a risk-based approach. In 2022, for example, we
deployed human trafficking online training to Western Union agent locations in Poland,
Romania, Moldova, and Hungary due to an influx of refugees as a result of the war
in Ukraine. For the same reason, 27 countries in European Economic Area received
dynamic messaging with a job aid to raise awareness on the increased risk of human
trafficking due to the war in Ukraine. Similarly, in August 2022 we launched targeted
human trafficking awareness training for approximately 13,000 agent locations in India to
increase the awareness in the region.

Educating Consumers
We work to educate the public about consumer fraud, which can occur in conjunction
with or advance modern slavery. We have tracked more than 336 million consumer fraud
touches toward our goal of 300 million by 20252. Content included notifications about the
2022 World Cup in Qatar and the Russian-Ukraine war.

Joining Forces to Prevent and Investigate Human Trafficking

We know our efforts to stop illicit activity through the use of our system are amplified
when combined with those of other organizations that share the same goals.
Collaboration and cooperation with external partners, including the sharing of techniques,
strategies, and intelligence, helps us combat threats posed by international criminal
organizations. Our Financial Intelligence Unit (FIU) works with external partners, such
as law enforcement, other government agencies, and non-governmental and private
organizations across the world, to address these risks.

Organizations and Associations:

In 2022, our Anti-Human Trafficking Initiative—a team aiming to bring awareness to human
trafficking issues to Western Union agents, industry partners, and others—continued to
collaborate with partners to execute its mission. These partners include various financial
institutions; nonprofits such as the International Justice Mission, Stop the Traffik, Child
Rescue Coalition, and Polaris; and both the International and National Centers for Missing
and Exploited Children (ICMEC and NCMEC). We continued our industry-first collaboration
with Child Rescue Coalition (CRC). This nonprofit’s mission is to rescue children from
sexual abuse by building technology for law enforcement to track, arrest, and prosecute
child predators. Western Union was the first financial institution in the world to leverage
CRC data to enhance our investigations and we have continued this analysis for over
three years. We are also a member of the U.S. Department of Homeland Security’s Blue
Campaign, a national public awareness movement aimed at combating human trafficking.

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In 2021, we refined our tracking methodology and the definition of this goal to focus on Consumer Fraud Awareness Touches, which
are derived from metrics tracked across various platforms, including paid media ads, social media (Facebook, Twitter, YouTube,
Community Management), outreach attendees, and wu.com/fraud awareness visits. Each platform may have a unique method for
quantifying individuals who have consumed anti-fraud content, based on reach, impressions, views, visits, and/or received physical
materials. Given that consumers may engage with our content through multiple channels, each “touch” may not be a unique consumer.

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 Law Enforcement
Our FIU continued to partner with law enforcement and nonprofits to better target and
disrupt human trafficking financial flows. In 2022, we assisted with more than 650 human
trafficking investigations, bringing our total to over 3,500 human trafficking investigations
since 2013 when our Anti-Human Trafficking Initiative was launched. This has contributed
to hundreds of arrests and the rescue of hundreds of victims. A large majority of these
investigations were advanced by referrals from Romanian and other law enforcement
entities in Europe. The team also continued work with INTERPOL and participate in both
the Europol Financial Intelligence Public Private Partnership Steering Group (EFIPPP) and
the Joint Money Laundering Intelligence Taskforce (JMLIT), led by the UK’s National Crime
Agency, on investigations tackling child sexual abuse and exploitation.

Supporting Ukraine
In 2022, in light of the tragic impact of Russia’s invasion of Ukraine, we suspended our
operations in Russia and Belarus. Though Russia was an important market for us, we
believe it was the right thing to do.

We have also been working to support the people of Ukraine, including the millions who
have been forcibly displaced. Our efforts include:

Fee-free money We have offered fee-free money transfers for our customers to
transfers: send funds to cards, bank accounts, or for cash pickup in Ukraine.

To directly support those affected by the humanitarian crisis,

Donations to support
Western Union, its employees, and the Western Union Foundation
humanitarian relief:
pledged up to $500,000 in aid to the people of Ukraine.

We have adapted our ID requirements to allow people displaced

Adapting system from Ukraine in neighboring countries to transact. We also
requirements: enabled money transfers sent to Ukraine to be paid out in cash at
Western Union locations in neighboring countries.

Our employees have mobilized to provide humanitarian aid such

as blankets, first aid kits and power banks for people displaced
Employee from Ukraine at Western Union agent locations, and border
volunteering: crossings in Hungary, Moldova, Poland, Romania, and Slovakia.
Western Union employees in Lithuania also volunteered with a
local food bank to arrange for packages of food to be distributed
to people displaced from Ukraine in Lithuania.

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 Steps Assessing
the Effectiveness
of Our Actions

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 As mentioned above, in 2020, we partnered with an external expert, who helped us identify
and prioritize Western Union’s salient human rights risks and assessed the degree to which
we managed risks.

With respect to our overall compliance program, over the past five years we have had
approximately 600 exams, audits, and third-party reviews across the 200 countries and
territories where we operate, including 81 exams, audits, and third-party reviews in 2022.
We regularly meet with regulators and banks from around the world to thoroughly review
our programs. Additionally, our internal audit department conducts over 50 reviews a year
to evaluate various aspects of our compliance program. These evaluations help us confirm
that our programs are operating effectively.

Western Union also publishes information on its efforts to prevent modern slavery and
human trafficking in its annual Environmental, Social, Governance (ESG) Report. The
ESG report is prepared in reference to the Global Reporting Initiative (GRI) Standards. It
also includes responses to select relevant metrics from the Sustainability Accounting
Standards Board (SASB) Standards as well as the U.N. Sustainable Development Goals.
This facilitates ESG ratings agencies to assess Western Union’s ESG performance and
supports data monitoring and measurement to assess the effectiveness of the Company’s
sustainability goals.

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 Looking
Forward

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 Western Union remains committed to leveraging our global footprint to help combat
human trafficking and modern slavery in 2023 and beyond. Going forward, we will continue
to look for new opportunities to engage our employees, customers, business partners,
and stakeholders on this important issue and will develop our efforts through various
measures, including:

• Enhancing our Vendor Risk Oversight program to increase due diligence risk
identification and implement an ongoing monitoring process to review vendors
throughout the engagement life cycle. We will continue to enhance program
governance for risk oversight, specifically as it relates to potential human trafficking or
modern slavery.
• Continuing to update and expand training materials and investigative resources for
employees and agents on how to identify, prevent, and report potential signs of human
trafficking and modern slavery.
• Expanding the reach of our global anti-human trafficking and modern slavery
initiatives through a focus on continuing to strengthen our partnerships with law
enforcement and non-governmental organizations in certain regions. For example,
we have committed to lead the 2024 ICMEC sponsored Law Enforcement – Financial
Institution Dialogue Series and will be responsible for organizing, developing,
and delivering several workshops throughout the year. The workshops will bring
together representatives from various law enforcement agencies and private sector
organizations to discuss the latest trends, issues and challenges facing financial
institutions in combatting child exploitation.

Consultation and Approval

This Statement is Western Union’s seventh statement. It was drafted in consultation with
several internal stakeholders from departments across the organization, who provided
feedback throughout the process. It was approved by pertinent affiliates of The Western
Union Company on the dates set out below.

Please direct any questions on this statement to Western Union’s Business Integrity Office
at: [email protected].

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 Andrew Pollock | Director Massimiliano Alvisini | Director
Western Union GB Limited Western Union Payment Services
June 19, 2023 Ireland Limited
June 14, 2023

Gregory Laurent | Director Graham Baker | Director

Western Union Financial Services Western Union Payment
(Australia) PTY LTD Services GB Limited
June 22, 2023 June 22, 2023

Graham Baker | Director Christian Hamberger | Director

Western Union Retail Services Western Union International Bank
GB Limited 26-June-2023
June 22, 2023

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