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Introduction
It continues to be a priority for Xceptor Ltd and its affiliated companies including holding companies (“Xceptor”) 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 the key activities we have undertaken during this financial year to combat modern slavery in our organization and supply chain.
Organization's structure
We are a provider of software and supporting professional services in the financial services sector amongst others. Xceptor has over 240 employees worldwide and has locations in UK, US, Singapore, and South Africa.
We have a global annual turnover of £40.3 million.
Our business
Our user base is global and focused primarily in key financial markets such as London, New York, and Singapore. We provide professional services support to our user base from South Africa.
Our supply chains
Our supply chains include large OEM software companies, such as Microsoft, with a comprehensive supply chain management process in place. We also have a long tail of small and medium-sized vendors that provide commoditized services.
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 in any part of our business. We continuously review and update all our policies.
Our policies 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 is not taking place anywhere in our supply chains. We have the following policies in place relevant to modern slavery, which we continuously review and update:
- Human Rights Policy [v3.2]
- Third Party Security Management Policy [v1.2]
- Employee Code of Conduct [v3.2]
- Equal Opportunities Policy [v3.2]
- Whistleblowing Policy [v1.2]
- Anti Bribery and Corruption Policy [v3.2]
- Anti Money-laundering Policy [v3.2]
- Talent Acquisition Policy [v3.4]
Due diligence processes for slavery and human trafficking
As a software business, our internal and external supply chains are generally at low risk of falling foul of child labour or forced labour laws. We provide some services from South Africa which we identify as a higher risk jurisdiction. In doing so, and throughout our business, we comply with all local labour laws. As part of our initiative to mitigate risks, we aim to pay at above market rates in South Africa.
We take steps to:
- Identify and assess potential risk areas in our supply chains.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains.
- Monitor potential risk areas in our supply chains.
- Protect whistle blowers.
Supplier adherence to our values and ethics
We have zero tolerance to slavery and human trafficking. Our supply chain compliance programme consists of requesting information where relevant when onboarding vendors regarding the programme they have to assure that human trafficking and slavery do not exist in their operations and supply chain.
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 require that new starters review and confirm their explicit adherence to our policies and periodically require that our employees review and recommit to our policies.
Our effectiveness in combating slavery and human trafficking
Following a review of the effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains, we are satisfied that all necessary steps have been taken to combat slavery and human trafficking.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Xceptor's slavery and human trafficking statement for the financial year ending 31 July 2023. It was approved by the board on 1 March 2024.
Michael Verhoeven, CEO
Xceptor Ltd
Date signed: March 4 2024