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. and Corvil Limited for themselves and on behalf of their ultimate parent company, and direct and indirect subsidiaries and affiliates (“Pico”, “we” or “our”). This statement highlights the steps taken by Pico during the financial year ended 31 December 2024 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 third party manufactured hardware, and related software and support services. Pico also supplies its own proprietary analytics and financial trading market access and data software, hardware and support, and software development 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, resellers, leading financial data centres and market venues, 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:
(a) for use in our own operations; (b) incorporated into our proprietary hardware and software products and services; or (c) resold to, or made available for use by, our customers for installation at their owned or leased sites or at our leased sites and managed by our customers or by Pico 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, infrastructure and connectivity hardware and software, as well as hard disks and other spare parts.
We recruit and select our own workers (“Picans”). Our global talent acquisition team is dedicated to finding skilled and qualified job seekers to fill open positions within our organisation; when appropriate, they also leverage recruitment agencies to expand the job seeker pool. We do not (nor do recruitment agencies we engage) demand fees from job seekers. All Picans are free to terminate their employment and are provided with a safe and secure working environment.
4. OUR POSITION
We continue to be committed to ensuring modern slavery and human trafficking is not present in our supply chain and our business.
We also continue to expect our suppliers and vendors to embed respect for human rights standards and decent working conditions in their own supply chains. To that end, we have continued to require that our suppliers 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 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, as well as their appetite to engaging with us and agreeing to implement corrective measures.
5. DUE DILIGENCE, RISK ASSESSMENT AND POLICIES
Pico has 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 Pico or on our behalf.
The International Trade Compliance Policy requires that qualifying suppliers, vendors, agents and other third parties: (a) be screened for trade sanctions, the results of which highlight any gross human rights abuses recorded or issued against entities, individuals and countries; and (b) complete a due diligence questionnaire confirming whether: (i) they have been a party to proceedings in any country for violation of applicable human rights law or standards; and (ii) they have policies and controls related to prohibition of human trafficking.
All Picans continue to be required to understand and follow the procedures detailed in our International Trade Compliance Policy to ensure appropriate screening is performed on qualifying suppliers, vendors, agents and other persons and legal entities to ensure commercial relationships and transactions do not present a risk of violation of applicable laws or of other improper behaviour that is not acceptable to Pico.
All job seekers who are offered a position at Pico are required to undergo verification checks to ensure they have the requisite skills and experience, and the right to work. Verification checks are crucial tools that assist us in revealing warning signs of modern slavery. Once employed, each Pican is required to complete compliance training and adhere to internal policies, such as the Pico Code of Business Conduct and Ethics and Policy Against Harassment and Discrimination.
The Pico Code of Business Conduct and Ethics prohibits conflicts of interest, discrimination, harassment, bullying and illegal business practices, and promotes ethical behaviour, such as financial integrity and fair dealing, and a “speak up culture”. Pico’s Policy Against Harassment and Discrimination, which is included in each of our regional Employee Handbooks, promotes equal opportunity for all and prohibits retaliation, coercion, intimidation and discrimination on any grounds.
If a risk of modern slavery or a violation of internal policies is identified or suspected, Picans are directed to report their concerns to the Pico Legal Department. Picans also have the option to report any suspected or actual violations anonymously via Pico’s whistleblowing hotline available by phone, email or web. Each report of suspected modern slavery offences or violations of internal policies will be investigated and addressed; if preliminary enquiries into the allegations reveal any risk to the safety of Picans or workers in our supply chain, we will engage relevant persons in positions of authority within our organisation and/or our supply chain to agree a corrective and risk-mitigation action plan. Failure to adhere to our internal policies, grievous abuses of human rights and modern slavery offences committed by Picans and our suppliers, vendors, agents and other third parties will not be tolerated.
6. TRAINING
We continue to recognise that our workforce is on the frontline and best placed to identify compliance risks. To empower our workforce, all employees continue to be 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. Completion of our new LRN™ 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. and Corvil Limited.
Jarrod Yuster, Chairman, Founder and CEO