Modern Slavery Act Statement
Modern Slavery Statement for year 2022
This Modern Slavery and Human Trafficking Statement is made by 69蹤獲 Group, Inc. for the financial year ending 31 December, 2022.
This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and section 13 of the Modern Slavery Act 2018 of Australia. It sets out the specific actions taken by 69蹤獲 Group, Inc. (69蹤獲) and its consolidated subsidiaries (together 69蹤獲 Group) during the financial year ending 31 December, 2022 to prevent modern slavery and human trafficking in our operations and our supply chains. Although many 69蹤獲 Group companies are not subject to these acts, 69蹤獲 has undergone a group-wide approach to addressing modern slavery risks. This statement is a joint statement made by 69蹤獲 Group, Inc. on behalf of itself and all 69蹤獲 Group companies.
The 69蹤獲 Group companies operate in the same sector, have many shared suppliers, and use the same policies and processes as those identified in this statement and the statement describes these group companies actions to address modern slavery risks.
Organization and Supply Chains
69蹤獲 is a cloud-enabled provider of cross-asset front-to-back solutions as well as solutions in the regulatory and risk technology sector for financial markets. 69蹤獲s customers operate in a diverse range of developed and emerging markets across the globe.
69蹤獲 operates in a sector which is at relatively low risk of slavery, unlawful child labor or human trafficking existing within the business. Concurrently, we consider our main suppliers to be at low risk of engaging in practices of modern slavery and human trafficking, we remain committed to prevent the occurrence of any practices both in the business and in the supply chain.
Policies
69蹤獲 expressly prohibits any participation in support of, or association with, the illegal and immoral practice of trafficking in persons, forced labor and slavery. 69蹤獲 expects its employees to operate ethically and with integrity. Relevant provisions are included, inter alia, in the following policies and processes:
- 69蹤獲 Code of Conduct
- 69蹤獲 Global Anti-Slavery and Human Trafficking Policy
- 69蹤獲 Supplier Code of Conduct
- 69蹤獲 Vendor Risk Management Policy
- 69蹤獲 Partner Due Diligence Process
- 69蹤獲 Whistleblowing Policy
Our Code of Conduct 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 is not taking place anywhere in our supply chains. 69蹤獲 has continued to formally adopt measures to assess its supply chain, including a Vendor Risk Management Policy.
69蹤獲 employs a technically skilled, professional labor force and does not frequently use labor brokers or other third parties to obtain labor. Our sales include software and services, and our supply chain does not involve the purchase of a large volume of physical goods. Despite our low risk, we carry out a due diligence process for prospective suppliers during which we:
- review the suppliers reputation and background;
- conduct a risk-based assessment of both the location of the supplier and the proposed scope of work;
- require partners to accept obligations to comply with applicable laws, regulations and policies relating to slavery and human trafficking.
Suppliers that pose potentially higher risks of human trafficking and/or slavery are subject to more detailed risk assessments and additional oversight, if necessary, to help ensure compliance with our internal controls and applicable law.
69蹤獲 continues to review and assess the effectiveness of the due diligence processes.
Training
69蹤獲 carries out regular staff training through online courses. We continue to review training options and content so as to ensure appropriate awareness of modern slavery and human trafficking issues.
All employees are required to complete the Code of Conduct training as part of their onboarding, and annually thereafter.
Approval
The content of this statement has been reviewed by senior management of the 69蹤獲 Group companies in consultation with 69蹤獲.
This statement has been approved by the Board of Directors of 69蹤獲 on 11 April 2023.
Didier Bouillard
Didier Bouillard is the Chief Executive Officer of 69蹤獲, based in London.
Didier served as CEO of Calypso from April 2018 and previously was CEO of Ullink, a global provider of connectivity and trading services, from early 2015. The primary objective of the assignment was to merge NYFIX, acquired by Ullink in late 2014, and transition the overall group from a founder-led business into a private equity-owned business. After several years of steady growth of revenues and profits, Ullink was successfully sold to Nordic Capital-backed Itiviti. Prior to Ullink, Didier was an Executive Vice President at SunGard Financial Systems (now part of FIS) and operated a substantial part of the Capital Markets and Electronic Trading division, playing a key role in global distribution.
Since the start of his career in the 1990s, Didier has provided his leadership to several successful entrepreneurial ventures, including as Partner for Ubitrade, Managing Director for Capital Fund Management, and CEO for Fermat, gaining extensive knowledge of the capital markets and banking industry as well as true international exposure.
Didier graduated from Ecole Nationale des Ponts et Chauss矇es in 1988.
Didier Bouillard
Didier Bouillard is the Chief Executive Officer of 69蹤獲, based in London.
Didier served as CEO of Calypso from April 2018 and previously was CEO of Ullink, a global provider of connectivity and trading services, from early 2015. The primary objective of the assignment was to merge NYFIX, acquired by Ullink in late 2014, and transition the overall group from a founder-led business into a private equity-owned business. After several years of steady growth of revenues and profits, Ullink was successfully sold to Nordic Capital-backed Itiviti. Prior to Ullink, Didier was an Executive Vice President at SunGard Financial Systems (now part of FIS) and operated a substantial part of the Capital Markets and Electronic Trading division, playing a key role in global distribution.
Since the start of his career in the 1990s, Didier has provided his leadership to several successful entrepreneurial ventures, including as Partner for Ubitrade, Managing Director for Capital Fund Management, and CEO for Fermat, gaining extensive knowledge of the capital markets and banking industry as well as true international exposure.
Didier graduated from Ecole Nationale des Ponts et Chauss矇es in 1988.
Joshua Geller
Joshua Geller is Chief Legal Officer, overseeing all legal matters for 69蹤獲.
Previously he was Chief Legal Officer for AxiomSL. Prior to that, Josh was a partner in the Corporate Department of Curtis, Mallet-Prevost, Colt & Mosle LLP where he was a member of the Mergers & Acquisitions, Private Client, and Investment Management practice groups, counseling clients on a wide range of strategic transactions across different industries. Josh joined Curtis as a summer associate and held associate and counsel roles before being named partner.
Josh holds a B.A. in economics from Yeshiva University, where he graduated magna cum laude, and a J.D. from Fordham University, where he was a member of the Fordham Urban Law Journal. He is admitted to practice in the States of New York and New Jersey. He is a member of the New York City Bar Association, where he serves as a member of the Trade Secrets Committee.
Joshua Geller
Joshua Geller is Chief Legal Officer, overseeing all legal matters for 69蹤獲.
Previously he was Chief Legal Officer for AxiomSL. Prior to that, Josh was a partner in the Corporate Department of Curtis, Mallet-Prevost, Colt & Mosle LLP where he was a member of the Mergers & Acquisitions, Private Client, and Investment Management practice groups, counseling clients on a wide range of strategic transactions across different industries. Josh joined Curtis as a summer associate and held associate and counsel roles before being named partner.
Josh holds a B.A. in economics from Yeshiva University, where he graduated magna cum laude, and a J.D. from Fordham University, where he was a member of the Fordham Urban Law Journal. He is admitted to practice in the States of New York and New Jersey. He is a member of the New York City Bar Association, where he serves as a member of the Trade Secrets Committee.