This statement has been prepared as part of XTX’s compliance with Section 54 of the Modern Slavery Act which requires certain firms to prepare a slavery and human trafficking statement for each financial year. This statement contains information in relation to the steps XTX has taken as of 30 June 2020 to ensure that slavery and human trafficking is not taking place: (1) in any part of its business; or (2) in any of its supply chains.
This statement applies to XTX Markets Limited and all companies which comprise the XTX group (“XTX”) including: XTX Research LLP, XTX Markets SAS, XTX Markets LLC, XTX Markets Pte. Ltd, XTX Markets Technologies Limited, XTX Markets LLP and XTX Securities Private Limited.
XTX Markets Limited is an English incorporated limited liability company and is authorised and regulated by the UK’s Financial Conduct Authority (“FCA”) as an IFPRU 730k investment firm.
XTX does not tolerate slavery, servitude, forced or compulsory labour (any behaviour that amounts to coercion (in the form of either direct threats of violence or more subtle forms of compulsion and/or where work or service is extracted from any person in the menace of any penalty and for which the person has not offered him/herself voluntarily) or human trafficking (known as “modern slavery” in this statement) within its business or supply chains.
XTX’s business and supply chain
XTX is an electronic market maker and liquidity provider which trades multiple asset classes (including equities, fixed income, exchange traded derivatives and FX) on exchanges and trading venues as well as providing liquidity in spot FX and spot precious metals (gold and silver) directly to eligible counterparties. XTX’s trading is either cleared via clearing brokers or directly with a central counterparty or given up to prime brokers.
To support XTX’s trading activities, XTX acquires trading data, purchases IT software and hardware and co-locates in certain exchanges.
XTX has offices in the UK, Paris, Singapore, New York and Mumbai.
XTX’s supply chain therefore comprises: exchanges (where XTX has exchange memberships) and banks (which act as executing or clearing brokers or as prime brokers); third party data providers, IT software and hardware providers and other IT infrastructure providers; and other miscellaneous suppliers such as office supplies and service providers.
Risk of modern slavery in XTX’s business and supply chains
XTX’s business is as a trading firm and therefore the risk of modern slavery in its business is low in comparison to firms which produce or sell physical goods.
XTX has 130+ employees or contractors who are based in the UK, Paris, Singapore, the US, India, Australia and New Zealand (“XTX staff”). Most XTX staff carry out highly skilled activities and therefore the risk of these individuals being subject to modern slavery is very low. All XTX staff are employed or engaged on contractual terms which comply with applicable law. The jurisdictions in which XTX operates require XTX to comply with a high standard of rights for workers – including in relation to pay, working conditions and health and safety.
XTX’s supply chain
Although there is a risk that XTX’s supply chain uses modern slavery practices, XTX considers this risk to be low. The following considerations apply:
When considering XTX’s supply chain, the highest risk suppliers are those producing physical goods and provision of managed services for the firm – such as IT hardware. These suppliers can be distinguished as higher risk as: they are unlikely to be regulated firms, they may rely on lower skilled workers to produce the goods, they may have their supply chain in higher risk jurisdictions, and they may be required to produce or source raw materials to produce their products.
XTX’s approach to preventing modern slavery in its business and supply chain
XTX will continue to monitor its policies and practices in relation to XTX staff to ensure it does not engage in any practice which amounts to modern slavery.
XTX’s supply chain
XTX adopts a risk based approach to its supply chain. For those suppliers which are identified as low risk (due to the considerations set out above), it does not consider it necessary to conduct enhanced due diligence or take any further action.
However, in respect of suppliers which XTX considers high risk of conducting its activities in a manner that involves modern slavery, XTX is considering implementing enhanced due diligence. This process will involve any high-risk new supplier being required to provide XTX information about the measures they have taken to reduce the risk of modern slavery in their business. This may involve, where applicable, requiring the firm to provide XTX with their Modern Slavery Statement and/or requiring the firm to confirm that modern slavery practices do not form part of their business or their own supply chain. In respect of existing high-risk suppliers, XTX may undertake due diligence on their supply chain as if they were a new supplier. High-risk suppliers may also be subject to on-going review. XTX will emphasise to high-risk supplier that XTX has a zero tolerance approach towards modern slavery.
To the extent XTX identifies practices which amount to modern slavery in the businesses or supply chains of its suppliers, this will be escalated to the Chief Compliance Officer, Chief Operating Officer and, if the supplier relates to IT infrastructure, the Head of IT Infrastructure and XTX will consider whether it will terminate or not renew its arrangements with any such supplier.
XTX training and policies in relation to modern slavery
XTX makes this Modern Slavery Statement available to all XTX staff on its intranet. In addition to this statement, XTX staff are subject to the following policies, which XTX consider relevant to the detection and prevention of modern slavery in its business and supply chains:
XTX will continue to assess the risk of modern slavery in its business and supply chains as its business continues to expand. Where necessary, XTX will revise its approach to combating practices of modern slavery in its business or supply chain. In assessing XTX’s anti-modern slavery practices, XTX will consider:
XTX Markets Limited is authorised and regulated by the Financial Conduct Authority (Firm Reference Number 711945) and is a provisionally registered swap dealer with the U.S. Commodity Futures Trading Commission.
XTX Markets Trading Limited is authorised and regulated by the Financial Conduct Authority (Firm Reference Number 949967)
XTX Markets LLC is registered with the Securities and Exchange Commission (SEC) as a broker-dealer (SEC#: 8-70009, CRD#: 289846) and its Designated Examining Authority is NYSE Chicago. The registered office of XTX Markets LLC is 64th Floor, 50 Hudson Yards, New York, NY 10001, USA.
XTX Execution Services LLC is registered with the Securities and Exchange Commission (SEC) as a broker-dealer (SEC#: 8-70532, CRD#: 309266) and its Designated Examining Authority is FINRA . The registered office of XTX Execution Services LLC is 64th Floor, 50 Hudson Yards, New York, NY 10001, USA.
XTX Markets SAS is registered with the Paris Commercial Court (Registre du Commerce et des Sociétés de Paris) under company number 844 280 388 R.C.S. Paris (VAT number FR68844280388) with its registered office at 3-5, rue Saint-Georges, TMF Pole, 75009 Paris, France and share capital of EUR 60,000,000
Société par actions simplifiée au capital de EUR 60,000,000. Siège social : 3-5 rue Saint-Georges - TMF Pôle - 75009 Paris. Immatriculée au Registre du Commerce et des Sociétés de Paris sous le numéro 844 280 388 R.C.S. Paris. VAT n° FR68844280388.
XTX Markets LLP is a SEBI registered stock broker (INZ000293058) at 74, Makers Maxity, 3 North Avenue, Bandra-Kurla Complex, Bandra (East), Mumbai, 400051, India. LLP Identification no: AAQ-0426