Updated June 2025.
This statement is published in line with section 54(1) of the UK Modern Slavery Act 2015.
FlexTrade is committed to improving our practices to combat Modern Slavery and Human Trafficking in our business and supply chain.
This statement is made by FlexTrade Systems, Inc. for and on behalf of itself and its global subsidiaries (collectively, “FlexTrade”, “we”, “us”, or “our”), in respect of FlexTrade’s actions and activities during the financial year ending 31 December 2024, pursuant to section 54 (1) ‘Transparency in Supply Chains’ provisions of the UK Modern Slavery Act 2015.
Definition of Modern Slavery:
Modern Slavery “refers to situations of exploitation that a person cannot refuse or leave because of threats, violence, coercion, deception, and/or abuse of power.” Modern Slavery is a crime resulting in an abhorrent abuse of human rights. It is constituted in the UK Modern Slavery Act 2015 by the offences of ‘slavery, servitude and forced or compulsory labour’ and ‘human trafficking’.
About FlexTrade UK Limited
FlexTrade UK Limited is a wholly owned subsidiary of FlexTrade Systems, Inc. (FlexTrade), which is a global leader in high performance multi-asset execution management and order management systems for equities, fixed income, foreign exchange, futures, and options. A pioneer in the field, FlexTrade is internationally recognized for introducing FlexTRADER®, the world’s first broker-neutral, execution management trading system, which allows clients to completely control and customize their execution workflows through a comprehensive ability to search/access liquidity while maintaining the confidentiality of their trading strategies.
We have a staff of approximately 650 from 10 countries across the globe. Through our work we also engage with numerous suppliers of goods and services.
Our commitment to the principles of the Modern Slavery Act 2015
FlexTrade is committed to the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking. We acknowledge the role that we can play to help to bring this about.
We are committed to acting ethically and with integrity in all our business relationships, and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business or in our supply chains.
We are an equal opportunities employer, fully committed to creating and ensuring an inclusive and respectful working environment for all our staff. We want all our staff to feel confident that they can report concerns without any risk to themselves.
Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.
We recognize that, as a purchaser of goods and services, we have the opportunity to influence good practices in the employment of people by other organizations.
We endeavour not to enter into business with any organization, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.
This Modern Slavery statement can be found on our website and may also be accessed via the Home Office modern slavery statement registry. Here are the steps FlexTrade has taken and continues to take to understand and minimize the potential risk of Modern Slavery in its business and supply chains.
Our supply chain
We procure goods and services from the UK and overseas suppliers.
We build relationships with our suppliers to ensure they understand our values and comply with our expectation and commitment to protect human rights and the environment. We have appropriate policies in place that underpin our commitment to ensure that there is no Modern Slavery and/or human trafficking in our supply chains or in any part of our business. We continuously review and update all our policies. As part of our procurement processes, we encourage all our suppliers to review and comply with all our policies.
Supply chain mapping:
As part of our supply chain due diligence reviews, we follow a risk-based approach and map our critical suppliers against tiers based on their criticality to FlexTrade. Critical and high-risk suppliers would fall under Tier 1 and the medium risk and low risk suppliers would fall under Tier 2 and Tier 3.
Our policies which relate to the Modern Slavery Act 2015
The following policies are available to all staff through the FlexTrade intranet:
- Code of Ethics and Business Conduct Policy
- Diversity and Inclusion Policy
- Conflict of Interest Policy
- Anti-Harassment and Anti-Bullying Policy
- Whistleblowing Policy
- Disciplinary Rules and Procedures
- FlexTrade Vendor Management Policy
- FlexTrade Anti-Corruption and Anti-Bribery Policy
Communication and Enforcement:
The above-mentioned FlexTrade policies are set out clearly, reviewed and approved on an annual basis. They are also accessible to all staff.
These policies set out the standards required by our staff and include details of the mechanisms in place which can be used to report issues or concerns, including matters impacting Modern Slavery relating to our organization.
Due Diligence
We have zero tolerance to slavery and human trafficking. We aim to ensure that all parties in our supply chain, including contractors, are encouraged to comply with our ethics and policies. Our compliance personnel responsible for due diligence belong to the following departments:
- General Counsel’s Office
- GRC Office
Due diligence measures include:
- To ensure that we do not inadvertently support slavery, we make our policies and processes known to staff and suppliers as a means of encouraging good practices.
- We ensure that all staff are legally entitled to work in the UK.
- We also ensure that any recruitment agency we utilize for the placement of temporary staff, follows the same requirements to confirm the identity and right to work of individuals placed with us.
- We also are cognizant of our right to challenge any abnormally low-cost tenders to ensure they do not rely upon the potential contractor practicing modern slavery.
Risk Assessment and Management
The two main areas of risk in relation to modern slavery at FlexTrade relate to our contractual arrangements and recruitment of staff. The steps that we take to manage these risks are outlined below.
FlexTrade carries out due diligence processes outlined above in relation to ensuring Modern Slavery and/or Human Trafficking does not take place in its organization or supply chains, including conducting a review of the controls of its suppliers.
FlexTrade has not, to its knowledge, conducted any business with another organization which has been found to have involved itself with Modern Slavery.
We will provide mandatory awareness to all staff on the Modern Slavery Act 2015 and inform them of the appropriate action to take if they suspect a case of modern slavery or human trafficking.
We will endeavour to take the necessary steps to have staff involved in buying or procurement, and the recruitment and deployment of workers, receive training in modern slavery and ethical employment practices.
To monitor and assess the effectiveness of our actions, FlexTrade looks at various performance indicators, including tracking the number and completion rates of internal compliance trainings that we have rolled out to employees, the proportion and number of complaints resolved and a number of due diligence procedures and preventive controls that we have developed and implemented with our suppliers and business partners.
Staff Awareness and Understanding
We aim to create awareness amongst all staff about the Modern Slavery Act 2015 and the appropriate action to take, if they suspect a case of Modern Slavery and/or Human Trafficking.
We will endeavor to take the necessary steps to have staff involved in buying or procurement, and the recruitment and deployment of workers, receive training in Modern Slavery and ethical employment practices.
Monitoring and evaluation of the Key Performance Indicators:
To monitor and assess the effectiveness of our actions, FlexTrade looks at various key performance indicators, including:
- Tracking the number and completion rates of internal compliance trainings that we have rolled out to employees.
- The proportion and number of complaints received and resolved.
- The due diligence procedure and preventive controls that we have developed and implemented with our suppliers and business partners.
Victim-centered approach: If any cases of Modern Slavery are uncovered by FlexTrade, we will take a victim-centered approach to remediation.
Transparency in our statement: If FlexTrade identifies case(s) of Modern Slavery and/or Human Trafficking in our supply chains, we endeavor to be transparent about them in our Modern Slavery statement, so that others can also learn from it and together we can improve our collective response to Modern Slavery.
When potential victims are identified: If we identify victims of Modern Slavery in our supplier relations, we will upon the advice of Counsel and Experts:
• notify the appropriate law enforcement agencies, and
• work openly and proactively with our suppliers to resolve issues and change working practices.
Contact details
If you suspect Modern Slavery, report it to compliance@flextrade.com
In addition, staff and external contacts can report any concerns in relation to potential Modern Slavery linked to FlexTrade’s operations to compliance@flextrade.com
If you suspect Modern Slavery, report it to the Modern Slavery Helpline on 08000 121 700 or the police on 101 and in an emergency call 999.
Approval by Corporate Governing Authority:
This statement is made by FlexTrade on a voluntary basis pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Modern Slavery and/or Human Trafficking statement for the financial year ending 31st December 2024. It was approved by an authorized representative of the parent corporation on 30th June 2025.
NAME AND SIGNATURE OF DIRECTOR/MEMBER/PARENT CORPORATION:
NAME OF COMPANY: FLEXTRADE SYSTEMS INC.
Name: Jamshaid Khan
Title: General Counsel