Modern Slavery Act Statement

Last updated: 07 May 2024

Policy statement

It continues to be a priority for ComplyAdvantage to ensure that we trade ethically, source responsibly, and work to prevent modern slavery and human trafficking throughout our organization and in our supply chain. This statement highlights our key activities during this financial year to combat modern slavery in our organization and supply chain.

ComplyAdvantage

IVXS UK Limited, also known as ComplyAdvantage, is a cloud-based Software as a Service (SaaS) company that, since launching in 2014, has been on a mission to reduce the risk of money laundering, terrorist financing, corruption, and other financial crime on a global scale.

ComplyAdvantage’s services provide dynamic real-time insight into financial crime risks.

ComplyAdvantage operates on a global basis, with offices in New York, London, Portugal, Singapore, and Romania.

Our supply chain is composed of suppliers of the tooling that enable us to create, maintain, and secure our estate.

Due to the nature of the services provided by ComplyAdvantage and the nature of the services typically procured, we assess that we are at a generally low risk of facilitating or otherwise being engaged in modern slavery.

Our policies on slavery and human trafficking

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 any part of our business. We continuously review and update all our policies.

Our policies and procedures reflect 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. We also have the following policies in place relevant to modern slavery, which we continuously review and update:

Code of Ethics
Our Approach to ESG
Procurement Manual
Employee handbook
Pre-employment screening policy (specifically right to work checks)

Due diligence processes for slavery and human trafficking

We understand that the following areas give rise to the highest modern slavery risks:

High-risk countries
Labor heavy products
Poorly regulated countries
Poorly regulated sectors

As part of our initiative to identify and mitigate risk, we carry out due diligence on all new suppliers and have a continuous assessment program in place, which includes the review of the company, the country in which they operate, 4th party suppliers where appropriate, and their policies and procedures.

As standard, we include clauses in our customer-facing contracts requiring the parties to comply with applicable modern slavery legislation and requiring notification in case of breach, following which a party may terminate the contract.

Supplier adherence to our values and ethics

We have zero tolerance for slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values and ethics, we have a supply chain compliance program in place.

Supplier due diligence is conducted at the point of contracting and on an ongoing basis throughout the term of an engagement, involving various departments throughout the organization, including:

Information Security
Legal
Human Resources

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide regular training to our staff.

Our effectiveness in combating slavery and human trafficking

We regularly review and measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains.

Further steps

Following a review of the effectiveness of the steps we have taken this year to ensure that there is no slavery or human trafficking in our supply chains, we intend to take the following further steps to combat slavery and human trafficking:

Increase staff awareness; and
Carry out audits on suppliers’ adherence.