Modern Slavery Statement

Marex Spectron Slavery and Human Trafficking Statement

This statement is made by Marex Spectron Group Limited on behalf of itself and its affiliates (collectively “Marex Spectron”), pursuant to section 54 of the Modern Slavery Act 2015 (the “Act”) for the financial year ending 31 December 2016.  The statement sets out the steps that we have taken to minimise the risk of modern slavery existing in our business or supply chains.

Marex Spectron is a leading global commodities brokerage headquartered in London, with offices in Europe, Asia and North America.

OUR VALUES AND POLICIES

As a global enterprise, we are rightly held to high standards in all that we do.  Marex Spectron recognises its corporate responsibility and is committed to maintaining a culture within which ethical behaviour is promoted.  Marex Spectron supports the Act’s objectives to eradicate modern slavery, which it defines as “slavery, servitude and forced or compulsory labour” as well as “human trafficking”.

While Marex Spectron recognises that our suppliers operate within different legal and cultural environments, our Supplier Code of Conduct outlines the basic ethical requirements that our suppliers must adhere to in order to do business with us, including our zero tolerance approach to modern slavery, namely:

  • Prohibition of slavery and forced labour: we condemn the abhorrent practices of slavery, forced and compulsory labour, servitude and human trafficking.  Be it through coercion, intimidation, verbal or physical threats of violence to the individual or their family, bondage or any other means that violates that individual’s liberty.
  • Prohibition of child labour: we are committed to ensuring all employees meet the minimum age for employment in the relevant country.
  • Remuneration: this must meet the minimum legal requirements of the relevant country in which the individual works.
  • Working conditions: reasonable health and safety measures are taken in maintaining a safe and hygienic working environment.

We reserve the right to terminate a supplier’s contract at any time should instances of modern slavery come to light.

RISK ASSESSMENT

In light of the regulatory landscape in which Marex Spectron operates, we believe we are at a low risk of modern slavery and human trafficking existing within our business.  Nonetheless, we have implemented an internal modern slavery policy in our Staff Handbook that sets out our zero tolerance approach to modern slavery and human trafficking in our business and supply chains.  The policy also provides details to employees on how to report any suspicions pertaining to modern slavery.  As per our existing whistleblowing policy, we actively support employees in raising concerns if they believe that anything illegal or unethical (including, but not limited to a breach of our policies) is taking place.

We consider there to be a greater risk of modern slavery and human trafficking occurring within our supply chains and have enhanced our due diligence procedures for suppliers during the on-boarding process.  We have also developed contractual representations prohibiting modern slavery and human trafficking, that we will require all suppliers to include in their contracts with us.  This will sit alongside existing ethical clauses like the prohibition of bribery.  This is in addition to our Supplier Code of Conduct.

TRAINING AND AWARENESS

Whilst all employees are already required to undertake training in ethics and required to abide by acceptable standards of behaviour, to ensure a suitable understanding of the risks of modern slavery and human trafficking, we are in the process of developing a modern slavery training package.  This training will be supported by our internal modern slavery policy.

This statement has been approved by Marex Spectron’s board of directors.

Ian Lowitt,

Chief Executive Officer

Marex Spectron Group Limited