We, IFX (UK) Ltd and our group companies (IFX, we or us), are opposed to all forms of slavery, including (without limitation) unpaid labour, human trafficking, sex trafficking and drug trafficking. We uphold ethical standards and act with integrity in all our business relationships and we require the same high standards from our contractors, suppliers and other business partners. We have issued this statement to demonstrate how we comply with the requirements of the UK Modern Slavery Act 2015 (the Act).
Our business
We are a regulated provider of foreign exchange and payment services. We have offices in the United Kingdom, Poland and the Dubai International Financial Centre.
Our supply chains
Our supply chains include:
- Financial institutions, liquidity providers and payment processors.
- Building and facilities management services.
- IT services.
Our policies
We have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We continuously review and update all our policies. For example:
- Our Group Anti-Slavery and Human Trafficking Policy reflects our commitment 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 are not taking place anywhere in our supply chains.
- Our Whistleblowing Policy promotes participation from employees in preventing and uncovering wrongdoing. Our employees are urged to express concerns regarding potential criminal activities or any form of misconduct occurring within IFX, involving its employees, customers, or third parties.
- We uphold a commitment to treating all employees with dignity and respect, fostering a discrimination-free and harassment-free workplace that rejects any form of bonded or forced labour. Furthermore:
- We maintain procedures for employment practices, aligning with applicable laws. These include thorough and fair recruitment processes, ‘right to work’ document checks, adherence to minimum working age regulations, and clear communication of employment terms through various channels such as written contracts and handbooks.
- Market-related pay and rewards are regularly reviewed, linked to financial services benchmarks. Employees undergo training covering essential human rights issues like diversity and inclusion, money laundering, and bribery and corruption.
Due diligence processes
As a regulated financial institution, a significant portion of our supplier base consists of other financial institutions and IT service providers. Consequently, we operate within a sector that is considered to have a relatively low risk for modern slavery and human trafficking.
To further mitigate risks, IFX remains committed to:
- Conducting due diligence on all relevant suppliers to ensure compliance with ethical and legal standards.
- Providing training for employees who are involved in procurement and supply chain management, relevant to the risks associated with modern slavery and human trafficking.
- Incorporating contractual obligations into our agreements with relevant suppliers to ensure their compliance with all applicable laws relevant to their supply of goods or services to us (wherever they may be in the world).
Training
To ensure understanding of the risks of modern slavery and human trafficking in our supply chains and our business, all employees who are involved in procurement and supply chain management are required to complete mandatory training, relevant to the risks with modern slavery and human trafficking.
Our effectiveness in combatting slavery and human trafficking
We remain vigilant in monitoring both the provision of our services and those we collaborate with to ensure we are effectively combating modern slavery and human trafficking.
Board approval
This statement is made pursuant to section 54(1) of the Act and constitutes our slavery and human trafficking statement for the financial year ending 30 April 2023.
This statement was approved by our board on 14 December 2023.
