Modern Slavery Statement

Introduction

This statement sets out Thalesians Ltd’s (the Company’s) actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2019 to 31 March 2020.

As part of the financial technology (FinTech) industry, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The Company adopts a zero tolerance to modern slavery, human trafficking, and all forms of corruption and bribery directly and indirectly associated with fraudulent or criminal acts and financial crime.

The Company fully supports the government’s objectives to eradicate modern slavery and human trafficking.

The Company sets high standards of impartiality, integrity, and objectivity, and will ensure that the Company’s activities operate to the highest level of ethical standards and sound governance arrangements.

Organisational structure and supply chains

This statement covers the activities of the Company:

  • We believe that we can help create a healthier, more sustainable human environment by applying the lessons we are learning from building some of the world’s most successful high- and medium-frequency trading systems to a wider range of data sets.
  • We call the new science – built on the foundation of quantitative finance, algorithmic trading, machine learning (ML), deep learning (DL), artificial intelligence (AI), reactive programming, and big data – neocybernetics.
  • The Level39 member fintech, the Company is a neocybernetics company using the new science and technology to revolutionise finance, insurance, transportation, shipping, and medicine in the United Kingdom and worldwide.
  • We do this by implementing real-time ML/AI software for neocybernetic systems, providing education, and consulting services.
  • We are experts in the application of ML/AI techniques to time series data, particularly Big Data and high-frequency data. Our areas of expertise include the mathematics of ML/AI, Deep Learning (DL), Python, and kdb+/q.

Our supply chain includes, but is not limited to:

  • Cloud computing companies, such as Rackspace;
  • Productivity and collaboration tool creators, such as Google and Atlassian;
  • Cloud-based accounting software vendors, such as Xero;
  • Online survey development cloud-based software as a service companies, such as SurveyMonkey;
  • Computer hardware manufacturers, such as Apple and Dell;
  • Vendors of programming languages and libraries for scientific computing (data science, machine learning applications, large-scale data processing, predictive analytics, etc.), such as Anaconda Inc. and the Apache Software Foundation;
  • Accounting and bookkeeping companies, such as JSA Group and Amelia Accounts;
  • Bookkeeping companies, such as Amelia Accounts;
  • Solicitors, specialising in various areas of our business activities.

Countries of operation and supply

The organisation currently operates in the United Kingdom.

The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

  • All potential workers undergo a selection process which rigorously checks the Right to Work in the United Kingdom.
  • All payments made are equivalent to, or more than, the National Minimum Wage (NMW).

The Company would like to reiterate our commitment to understanding modern slavery risks and ensuring that there is no modern slavery in our own business and our supply chains.

The Company avoids involvement in activities considered to be at high risk of slavery or human trafficking.

Responsibility

Responsibility for the organisation’s anti-slavery initiatives is as follows:

  • Policies: the Company’s directors are responsible for putting in place and reviewing policies and the process by which they are developed.
  • Risk assessments and due diligence: the Company’s directors are responsible for conducting relevant risk assessments and due diligence.
  • Training: the Company’s directors are responsible for organising mandatory training on the Modern Slavery Act 2015 for the Company’s staff, consultants, and business partners.

Relevant policies

The Company operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Whistleblowing policy: The Company encourages all its workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of, the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers, or others who have concerns can complete our confidential disclosure form: https://www.surveymonkey.co.uk/r/B8DZTDF
    Alternatively, those who hold information that could lead to the identification, discovery, and recovery of modern slavery or human trafficking victims in the UK, can contact the Modern Slavery Helpline on 08000 121700.
  • Employee code of conduct: The Company’s code makes clear to employees the actions and behaviour expected of them when representing the Company. The Company strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
  • Supplier code of conduct: The Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their workers’ working conditions. However, serious violations of the Company’s supplier code of conduct will lead to the termination of the business relationship.
  • Recruitment policy: All potential workers undergo a selection process which rigorously checks the Right to Work in the United Kingdom. All payments made are equivalent to, or more than, the National Minimum Wage (NMW).
  • Recruitment agency policy: When using recruitment agencies, the Company uses only specified, reputable agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
  • Victim support: If you think you are a victim of modern slavery or human trafficking, please contact the Modern Slavery Helpline on 08000 121700. Trained operators will help you to understand what is available – including information, advice, and ways to access government-funded support. The Modern Slavery Helpline is confidential, and, if you don’t want to give your name, that is ine.

Due diligence

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence and reviews include:

  • mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
  • evaluating the modern slavery and human trafficking risks of each new supplier;
  • reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
  • conducting supplier audits and assessments which have a greater degree of focus on slavery and human trafficking where general risks are identified;
  • creating an annual risk profile for each supplier;
  • taking steps to improve substandard suppliers’ practices, including providing advice to suppliers and requiring them to implement action plans;
  • invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Performance indicators

The Company has reviewed its key performance indicators (KPIs). As a result, the Company

  • is requiring all staff to have completed training on modern slavery by 2019.06.30;
  • has developed a system for supply chain verification in place since 2019.05.24, whereby the Company evaluates potential suppliers before they enter the supply chain; and
  • reviewing its existing supply chains completed on 2019.05.24, whereby the organisation evaluates all existing suppliers.

Training

The Company requires all staff within the organisation to complete training on modern slavery by 2019.06.30.

The Company requires all staff to complete an online training course by 2019.06.30.

The Company’s modern slavery training covers:

  • our business’s purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;
  • how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
  • how to identify the signs of slavery and human trafficking;
  • what initial steps should be taken if slavery or human trafficking is suspected;
  • how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
  • what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority, and “Stronger together” initiative;
  • what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
  • what steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation’s supply chains.

Awareness-raising programme

As well as training staff, the organisation has raised awareness of modern slavery issues by circulating a series of emails to staff.

The emails explain to staff:

  • the basic principles of the Modern Slavery Act 2015;
  • how employers can identify and prevent slavery and human trafficking;
  • what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
  • what external help is available, for example, through the Modern Slavery Helpline.

Directors’ approval

This statement was approved on 2019.05.27 by the Company’s Directors, who review and update it annually.