MODERN SLAVERY ACT TRANSPARENCY STATEMENT
FINANCIAL YEAR END 31 DECEMBER 2021
1. To comply with the requirements 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 December 2021 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 is incorporated in the United Kingdom and is regulated by the Financial Conduct Authority. Tradeweb builds and operates electronic over-the-counter marketplaces, and has a permanent presence in England with branches in Singapore
and Hong Kong. Tradeweb’s business outside of these locations is carried on primarily within Europe and Asia.
3. Given the nature of its business, Tradeweb assess that the risk of Modern Slavery in its business and supply chain is low. As a service provider, Tradeweb’s largest resource is its employees and any, occasional, agency workers. Our largest exposure to possible Modern Slavery concerns would be in our supply chain, and we maintain internal policies to minimise the potential risk exposure from organisations that provide services to, or items for Tradeweb’s own use, including:
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. Tradeweb is not aware of any Modern Slavery in any part of its business or supply chain, and is dedicated to ensuring its business and supply chains are free of Modern Slavery. Tradeweb acts ethically and with integrity in all its business dealing and relationships and is committed to improving its practices to combat Modern Slavery.
5. During the financial year ending 31 December 2021 Tradeweb has taken the following steps to ensure that Modern Slavery is not taking place in any of its supply chains and in any part of its business:
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.
6. In the next financial year and in accordance with good practice standards, Tradeweb will continue to ensure compliance with the MSA.
7. This statement was approved by the Board of Tradeweb on 23 February 2022 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