MODERN SLAVERY ACT TRANSPARENCY STATEMENT
FINANCIAL YEAR END 31 OCTOBER 2018
1. To comply with the requirement of Section 54 of the Modern Slavery Act 2015 (the “MSA”), this statement is given by Tradeweb Europe Limited (“Tradeweb”) for its financial year which ended on 31 October 2018 and contains details of the steps that Tradeweb has taken to ensure that neither slavery nor human trafficking (together, “Modern Slavery”) is taking place in the organisation or its supply chains.
2. Tradeweb builds and operates electronic over-the-counter marketplaces. Tradeweb has a permanent presence in England and branches in Singapore and Hong Kong. Tradeweb’s business outside of these locations is carried on primarily within Europe and Asia.
3. Tradeweb is incorporated in the United Kingdom and is regulated by the Financial Conduct Authority. As a service provider, Tradeweb’s largest resource is the employees and any, occasional, agency workers. Other supply chains of the organisation provide items for Tradeweb’s own use:
a. Office equipment and stationary;
b. Legal, accounting and professional advisers;
c. IT equipment and IT related Services;
d. Marketing materials and marketing related services;
e. HR related services;
f. Financial related services; and
g. Catering Services.
4. During the financial year ending 31 October 2018 Tradeweb:
a. recruited and employed staff and procured and engaged suppliers and advisers in each case in accordance with robust policies and procedures which seek to minimise the risk of Modern Slavery occurring in Tradeweb, including by only engaging with reputable and credible suppliers and advisers;
b. carried out an appropriate level of due diligence on its existing supply chains which included seeking confirmation from our vendors / service providers that they are aware of the MSA and comply with it;
c. reviewed supplier and adviser engagements to ensure compliance with all applicable laws (which would include the MSA);
d. ensured that our employees have a high level of understanding of the risks of modern slavery and human trafficking in our business through training; and
e. maintained robust policies and procedures to require employees of Tradeweb to raise concerns about any issue at the earliest possible stage. These policies and procedures reflect our commitment to paying people fairly and properly for their work, acting ethically and with integrity in all our business relationships and enforcing effective systems and controls to safeguard against Modern Slavery within our business or supply chains.
5. In the next financial year and in accordance with good practice standards, Tradeweb will continue to ensure compliance with the MSA.
6. The Home Office began a compliance audit of organisations required to publish a Modern Slavery statement on 31 March 2019, therefore, Tradeweb may be subject to a review and audit during the next financial year.
7. This statement was approved by the Board of Tradeweb on 2 May 2019 and is signed by a Director of Tradeweb.
8. This statement will be reviewed annually.
9. Questions, comments and requests regarding this statement are welcomed and should be addressed to Help@Tradeweb.com.
Enrico Bruni, Director
Tradeweb Europe Limited