Introduction
The OSTTRA Group Ltd. and its subsidiaries and affiliates (collectively “OSTTRA”) is committed to ensuring that we – and our suppliers – operate in compliance with all applicable laws as well as in accordance with the highest standards of ethical behaviour, as outlined in the OSTTRA Code of Conduct. OSTTRA supports and respects the protection of internationally recognised human rights and endeavours to make sure that we are not complicit in human rights abuses. Accordingly, we do not tolerate modern slavery or human trafficking in our organisation or supply chain.
Our business
OSTTRA is a joint venture between CME Group, the world’s leading and most diverse derivatives marketplace, and S&P Global, a world leader in critical information, analytics, and solutions. OSTTRA includes trade processing and risk mitigation operations.
The combination of MarkitServ, TriOptima, Traiana and Reset’s complementary offerings provides clients with enhanced platforms and services for global OTC markets across interest rate, FX, equity and credit asset classes. OSTTRA gives market participants a more efficient front-to-back workflow with enhanced connectivity and improved trading certainty. As a result, OTC market participants are able to improve risk management and streamline their post-trade operations.
Organisational structure
OSTTRA Group Ltd is a UK tax domiciled company incorporated in Bermuda, headquartered in London, with approximately 1200 employees in 11 countries worldwide.
Our supply chain
OSTTRA’s supply chain largely consists of professional services providers such as consultants, accountants, law firms, contractors, software services, and data and content providers. OSTTRA also uses suppliers of IT, office equipment, facilities management, print production and publication distribution services.
Given the nature of OSTTRA’s business, we believe there is minimal risk of practices that support, facilitate or are complicit with modern slavery, within either OSTTRA or our supply chain. Generally, we procure computer equipment as well as office supplies, equipment and services for the daily running of our businesses. In addition, from time to time, we use third party vendors and contractors for technology support and development, and for various advisory services. OSTTRA does not manufacture or sell any physical goods and, therefore, we have no supply chain relating to such activities. Nevertheless, we require that all vendors with whom we have a master services agreement agree to perform at the highest level of business and professional ethics, and to ensure that they and their subcontractors comply with all applicable anti-slavery and human trafficking laws, including but not limited to the UK Modern Slavery Act. We have also embedded these expectations in our purchase order forms and new vendor onboarding forms.
OSTTRA policies on slavery and human trafficking
OSTTRA, CME Group and S&P Global have a zero-tolerance approach to modern slavery and human trafficking, which is confirmed in many of their corporate policies and procedures, including the Codes of Conduct Third Party/Vendor Codes of Conduct and their Human Rights and Labour Practices policy. These documents articulate our commitment to respecting and promoting fundamental human rights, which we view as a key component of responsible corporate citizenship. In addition to supporting the fundamental principles contained in the United Nations Universal Declaration of Human Rights, we are committed to working with suppliers to help uphold ethical human rights standards.
Due diligence and further steps
OSTTRA has determined that the majority of its suppliers operate in areas considered to be at a low risk of supporting or being complicit in forced labour or human trafficking.
OSTTRA has implemented procedures to assess the risk of new vendors at onboarding and we require suppliers to affirm their commitment to eradicating modern slavery and human trafficking.
OSTTRA plans to continue to monitor its business for potential risks related to slavery and human trafficking and other best practices adopted in our industry.
Reporting of Violations of the Slavery or Human Trafficking
We provide the means (including anonymous helplines) for employees and other third parties to make confidential reports, raise complaints and request guidance about compliance or ethical issues, including matters referred to in our policies. These helplines provide another avenue through which we can ensure that any potential slavery, human trafficking or wider human rights impacts are identified and dealt with appropriately in our organisation. Each report of suspected misconduct is investigated by appropriate groups within our organisation and where a violation of policy is substantiated corrective action is taken.
Training
To maintain awareness and ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, all employees have been made aware of this statement and reminders will be issued on an annual basis.
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This statement is made pursuant to section 54(1) of the Modern Slavery Act of 2015 and constitutes the slavery and human trafficking statement from 1st November 2023 for OSTTRA Group Ltd. and subsidiaries to which the Act applies. Signed by:
John Stewart
Co-CEO and Chief Operating Officer