1. INTRODUCTION
This statement is made pursuant to section 54 of the Modern Slavery Act 2015. The Modern Slavery Act 2015 is a piece of legislation enacted in the United Kingdom to combat slavery, servitude, forced or compulsory labour, and human trafficking.
It is published by Pico Global Ltd. for itself and on behalf of its parent company, and direct and indirect subsidiaries and affiliates (“Pico” or “we” or “our”).
This statement highlights the steps taken by Pico during the financial year ended 31 December 2023 to prevent modern slavery and human trafficking taking place in its supply chain.
2. OUR BUSINESS
Pico operates in the financial technology (“fintech”) sector to provide business-to-business services and products to domestic and international customers active within the financial services industry. Pico has offices in North America, Latin America, Europe, the Middle East, Asia and the Pacific.
Pico provides electronic trading infrastructure, network, cloud and financial market data services, as well as analytics and financial trading market access and data software, and technology hardware and support services.
3. OUR SUPPLY CHAIN
As a global service provider of fintech solutions, our supply chain is global and multi-tiered.
We work with technology partners , as well as leading financial data centres and market venues. We also work with hardware manufacturers and software developers.
Our centralised procurement team sources a range of products and services from our tier-1 suppliers, the vast majority of which are large, established tier-1 IT vendors with global distribution capabilities and their own established modern slavery compliance programs, human rights policies and supplier codes of conduct.
The products and services we source are destined for use in our own operations or those of our customers who ask us to install them at their owned or leased sites or to manage them on their behalf. Examples of the products and services procured by Pico include public and private cloud space, server and network switches, colocation and other connectivity cabling and equipment, financial market data, as well as infrastructure and connectivity hardware and software.
4. OUR POSITION
We are committed to ensuring modern slavery and human trafficking is not present in our supply chain and our business.
We expect our suppliers and vendors to embed respect for human rights standards and decent working conditions in their own supply chains. To that end, suppliers are required to provide contractual assurance by agreeing to comply with applicable laws and regulations, which include laws related to anti-bribery and corruption, modern slavery and human rights.
Whenever and wherever possible, we will take appropriate steps to ensure that all those who work directly or indirectly for Pico do so in an environment in which their fundamental human rights and freedoms are respected. Our ability to take appropriate steps will depend on the supplier, vendor or agent, where they sit within our supply chain and their appetite to agreeing and implementing corrective measures.
5. DUE DILIGENCE, RISK ASSESSMENT AND POLICIES
Pico has instituted a global, International Trade Compliance Policy that addresses vendor/supplier due diligence, and provides guidance to Pico personnel on the signs to look out for and how to conduct due diligence and risk assessments on vendors, suppliers, agents and other third parties that wish to work with us or on our behalf.
The International Trade Compliance Policy requires that qualifying suppliers, vendors, agents and other third parties be screened for trade sanctions, the results of which highlight any gross human rights abuses recorded or issued against entities, individuals and countries. It also requires that qualifying suppliers, vendors, agents and other third parties complete a due diligence questionnaire confirming whether: (a) they have been a party to proceedings in any country for violation of applicable human rights law or standards; and (b) they have policies and controls related to prohibition of human trafficking.
All Pico personnel are required to follow the procedures detailed in our International Trade Compliance Policy to ensure that parties are properly screened and authorised before they occur, and that a relationship with a potential third party does not present an unacceptable risk of violation of applicable laws or of other improper behaviour to Pico.
If a risk is identified, Pico personnel are directed to report their concerns to the Pico Legal Department. Pico personnel can also report any suspected or actual violations anonymously via Pico’s whistleblowing hotline available by phone, email or web.
6. TRAINING
We recognise that our workforce is on the frontline and best placed to identify compliance risks. To empower our workforce, all employees are required to complete annual compliance training, which includes training on anti-bribery and corruption, preventing discrimination and harassment and Pico’s Code of Conduct. Training is supplemented, and supported, by internal policies, such as Pico’s Policy Against Workplace Harassment and Pico’s Code of Conduct.
Compliance training courses are required to be completed annually by each Pico employee. Completion of our Thomson Reuters training courses is also tracked through an annual certification process so that any delays or non-compliance are flagged and can be escalated as appropriate.
Approved by the Board of Directors of Pico Global Ltd.