Legatus Trading Ltd Modern Slavery and Human Trafficking Policy

Purpose

Legatus Trading Ltd is committed to preventing modern slavery and human trafficking within our operations, supply chains, and partnerships. We recognize that modern slavery is a violation of fundamental human rights and takes various forms, such as forced labor, bonded labor, child labor, and human trafficking. This policy outlines our commitment to addressing modern slavery in compliance with the UK Modern Slavery Act 2015, EU legislation, and best practices to uphold a fair and transparent working environment.

Scope

This policy applies to all employees, contractors, suppliers, and business partners associated with Legatus Trading Ltd. It covers all activities within our company and our entire supply chain.

Policy Statement

Legatus Trading Ltd has zero tolerance for modern slavery and is dedicated to ensuring that slavery and human trafficking do not occur in any part of our business or supply chain. We are committed to acting ethically and with integrity in all business dealings, implementing and enforcing effective systems and controls to prevent and address modern slavery.

Supply Chain Due Diligence

We carry out rigorous due diligence on our suppliers and partners to assess the risk of modern slavery and human trafficking. We prioritize suppliers with strong labor standards and ethical practices.

Risk Assessment & Management

We assess and monitor modern slavery risks within our operations and supply chain, especially in high-risk areas. Our risk management approach involves ongoing analysis, supplier audits, and stakeholder consultations.

Supplier Code of Conduct

Legatus Trading Ltd has established a Supplier Code of Conduct that outlines our expectations for ethical labor practices, including the prohibition of forced labor, child labor, and any form of exploitation. All suppliers must adhere to this code as a condition of their engagement with us.

Employee Awareness and Training

We provide training to employees, management, and stakeholders on identifying, preventing, and reporting instances of modern slavery and human trafficking. Training raises awareness of our policy and empowers employees to act if they encounter issues.

Reporting Mechanism and Whistleblowing

We maintain a secure and confidential reporting mechanism for employees, contractors, and suppliers to report any suspected instances of modern slavery without fear of retaliation. Reports can be made anonymously, and all disclosures are treated with confidentiality and investigated promptly.

Continuous Improvement

We review and update our policies and procedures regularly to reflect changes in legislation, international standards, and best practices in modern slavery prevention. We aim to continuously strengthen our practices to mitigate risks effectively.

Compliance and Monitoring

Legatus Trading Ltd undertakes regular audits and inspections of our supply chain to ensure compliance with this policy. Any breach of this policy by employees, contractors, or suppliers will be dealt with through appropriate disciplinary actions, which may include contract termination.

Accountability and Responsibility

The Board of Directors and senior management of Legatus Trading Ltd hold ultimate responsibility for ensuring compliance with this policy. Operational responsibility is assigned to the Compliance and Procurement teams, who ensure that our systems, controls, and practices align with this policy.

Reporting Modern Slavery

We encourage anyone associated with Legatus Trading Ltd to report any concerns or suspicions related to modern slavery. Concerns can be reported through our dedicated hotline or directly to our Compliance team at [email protected]. We ensure that all reports are handled discreetly and investigated thoroughly.

Legal Compliance

Legatus Trading Ltd adheres to the Modern Slavery Act 2015 (UK) and relevant EU legislation, including the EU Charter of Fundamental Rights and the EU Directive on Human Trafficking. This policy is crafted to ensure compliance with these legal frameworks and to demonstrate our commitment to ethical business practices.

Policy Review

This Modern Slavery Policy will be reviewed annually or as necessary to ensure its relevance and effectiveness. We commit to transparent reporting on our actions against modern slavery and any identified risks or incidents, as required under the Modern Slavery Act 2015.

Endorsement

This policy has been approved by the Board of Directors of Legatus Trading Ltd and is endorsed by senior management as a reflection of our commitment to abolishing modern slavery in all forms.

Approved By:-

Mr. Timothy Cruise
Legatus Trading Ltd
5 Brayford Square
London
United Kingdom
E1 0SG