Modern Slavery Statement 2021

Introduction

To comply with the requirement of Section 54 of the Modern Slavery Act 2015 (the “MSA”), this statement is given by Ediphy Group Ltd and its subsidiaries (collectively, “Ediphy”). In its support of the goals set forth in the Act, Ediphy has produced the following Modern Slavery Statement (the "Statement") setting out its policies and procedures in respect of modern-day slavery and human trafficking.

Our Business

The Ediphy companies are incorporated in the United Kingdom and the Ediphy Markets Ltd subsidiary is additionally regulated by the Financial Conduct Authority. Ediphy builds and operates technology and execution services for institutional capital markets.

Our Supply Chain

Due to the nature of Ediphy's business, the overall risk for the facilitation of modern slavery and human trafficking in our business or amongst our suppliers is low. As a service provider, Ediphy’s largest resource is the employees and any, occasional, agency workers. Other supply chains of the organisation provide items for Ediphy’s own use:

a. Legal, accounting and professional advisers;

b. IT equipment and IT related Services;

c. Marketing materials and marketing related services;

d. Office equipment and stationary;

e. HR related services; and

f. Financial related services.

Our Policies Concerning Modern Slavery

Ediphy strongly condemns the use of slavery and human trafficking in any circumstance. As a responsible employer, each employee is made aware of Ediphy’s expectations concerning fair working conditions and safe working environments during their mandatory new hire orientation training. New employees are also introduced to Ediphy’s robust policies and procedures, requiring employees to raise concerns about any issue at the earliest possible stage. These policies and procedures reflect our commitment to paying people fairly and properly for their work, acting ethically and with integrity in all our business relationships and enforcing effective systems and controls to safeguard against Modern Slavery within our business or supply chains. All Ediphy employees can easily access the Policies in the Employee Handbook, which is located on Ediphy’s intranet, as well as a copy of this statement, which is available on Ediphy’s website (ediphy.io).

Our Vendor Due Diligence Process and Supplier Code of Conduct

Ediphy procures and engages suppliers and advisers in each case in accordance with robust policies and procedures which seek to minimise the risk of Modern Slavery occurring in Ediphy, including by only engaging with reputable and credible suppliers and advisers. An appropriate level of due diligence on its existing supply chains is carried out on a periodic basis, which includes seeking confirmation from our vendors / service providers that they are aware of the MSA and comply with it.

Approval

This statement has been reviewed and approved by the Firm’s board of directors. The statement will be reviewed annually. Questions, comments and requests regarding this statement are welcomed and should be addressed to compliance@ediphy.io

Christopher Murphy

Director, Ediphy Group Ltd.