Modern slavery and ethical conduct.

• 01

  Identify the companies and beneficial owners we deal with, so far as a firm of our size reasonably can.

• 02

  Refuse or stop work where we have a credible suspicion of modern slavery or related abuse.

• 03

  Require counterparties, in mandates and introductions, to confirm that their labour and supply practices are lawful.

• 04

  Keep a written record of KYC received and of any concern raised.

• 05

  Report a suspected offence to the appropriate authority where we are required to, or where it is clearly right to do so.

We do not use forced labour. We do not withhold identity documents or wages. We expect the same of agents and counterparties introduced through us.

Voluntary statement · Reviewed by the Director · Updated as the firm grows

No employee or agent may offer, pay, solicit or accept a bribe. Facilitation payments are not permitted. Gifts of more than token value must be disclosed to the Director.

We will not proceed with a transaction where a party appears on an applicable sanctions list, or where the payment route cannot be explained.