Modern Slavery Act

Eisler Capital (UK) Ltd. and its Group companies (together “Eisler”) is committed to addressing the requirements placed on it by the UK Modern Slavery Act 2015 (the “Act”). While this is a UK Act, Eisler applies policies and processes on a group-wide basis irrespective of where our companies, people, clients and supply chain providers are located.

This statement is made pursuant to section 54 of the Act and constitutes Eisler’s statement as required by the Act for our financial year ended 31 December 20201.

Organisational structure

Eisler has undertaken an investigation of its corporate structure and business practices. While certain of Eisler’s group companies do not carry on business in the UK and are therefore not subject to the Act, Eisler nevertheless applies its commitment to all group companies.

Supply chains and due diligence procedures

Eisler is committed to ensuring that its supply chain is free of any slavery and/or human trafficking. Eisler will not knowingly support and/or do business with any suppliers who are involved in slavery.

Eisler’s direct supply chain is limited and includes, for example, financial data providers and outsourced administration and IT service providers. Eisler also uses a number of third party suppliers as part of its indirect supply chain, relating to non-core functions such as cleaning, catering, office services and brand marketing.

In order to fulfil its obligations under the Act, Eisler:

  • undertakes due diligence to assess the nature and extent of its exposure to the risk of slavery;
  • requests information regarding third party suppliers’ working practices and requires the relevant key supplier to confirm that it is aware of, and complies with, its obligations under the Act;
  • communicates to potential key suppliers that we have a zero-tolerance policy with regards to slavery.

Training and policies

Training is fundamental to raising awareness of slavery issues. Eisler has published this statement on its website and every employee has been instructed to read it and adhere to its principles. On an annual basis all employees are reminded of their obligations to the Act as part of a formal training programme.

Monitoring and adherence

Responsibility for ensuring and monitoring adherence to this policy within Eisler rests with all its employees. Employees who interact with third party suppliers are additionally charged with monitoring adherence to this statement by those third parties, to the extent they are able. Employees who are aware of, or suspect, any violation of the Act are required to report such conduct to the Chief Compliance Officer, or to follow Eisler’s whistleblowing policy should they feel uncomfortable reporting directly.

Measuring success

Eisler uses the following key performance indicators to measure the effectiveness of its approach to modern slavery:

  • effective deployment of training to key stakeholders;
  • completion of due diligence procedures undertaken on key suppliers;
  • ongoing monitoring of key suppliers; and
  • effective avenues for employees and/or suppliers to escalate modern slavery issues and concerns.

Approval procedure

This statement, which will be reviewed annually and updated as required, has been approved by Eisler’s governing body on [DATE TBD].