Modern Slavery Statement

BOXT Limited is committed to preventing modern slavery and human trafficking in all of our business activities. We recognise that modern slavery is a serious crime and a violation of fundamental human rights. As such, we are dedicated to ensuring that our business and supply chains are free from any form of modern slavery.

We are committed to conducting business in an ethical and responsible manner, including by carrying out our activities in a manner that respects and supports the protection of human rights through seeking to:

1. Eliminate discrimination in employment

2. Prohibit modern slavery, including child and forced labour; and

3. Eradicate harassment and physical or mental abuse in the workplace.

As part of the Brookfield Asset Management group, BOXT is committed to aligning our business practices with the overall group.  Brookfield Asset Management Modern Slavery statement can be found >> https://www.brookfield.com/sites/default/files/2022-06/Modern%20Slavery%20Statement.pdf

Scope

The UK Modern Slavery Act 2015 (“MSA UK”) requires BOXT to set out the steps taken to identify and mitigate the risks of slavery and trafficking in its business and supply chains in the UK. This Statement is made in accordance with MSA UK and relates to the period 1st January 2022 to 31st December 2022.

This Statement has been prepared and approved by the Board of Directors.

We recognise that the risks of modern slavery and human trafficking are complex and evolving and we continue to work to address these in our business. Our approach and processes are reviewed periodically and, where appropriate, updated as necessary to reflect changes in circumstances and practice.

Our Business Activities 

Assessing Modern Slavery Risk

Our approach to addressing modern slavery is designed to be commensurate with the risks we face.

Modern Slavery Risk Profile

1. Third Party Vendors

Given the nature of our business and the location in which we operate, third-party suppliers and vendors used across BOXT business generally fall under the below categories:

Outsourcers: where a business activity or professional service is outsourced to another organisation.

Vendor Software Providers: this includes off-the-shelf software, including hardware vendors used to facilitate business processes.

Cloud/Hosted IT Services: encompasses a range of IT services provided in various formats.

Professional services: includes consulting, legal, accounting, training, audit, banking and education.

Data Providers: organisations that provide data, which feed into BOXT’s systems and terminals that provide access to market data.

Office Maintenance: includes building repairs and maintenance, cleaning, security, utilities.

We believe that the risk of modern slavery within these providers is low, this assessment is based on the regulated industries in which they operate and the skill of the professionals providing such services. We acknowledge that, to a lesser extent, we engage with suppliers who may be considered higher risk in terms of modern slavery, such as suppliers of office stationery and cleaning services. We recognise that each of our suppliers has their own supply chains and our vendor assessments factor in this risk to the extent possible. We currently have limited visibility of these extended supply chains.

2. Employees

Our people drive our success.  All employees of BOXT are employed in the UK and the majority are professional and administrative staff.  BOXT has human resource policies, procedures and processes in place designed to protect against modern slavery and human trafficking in BOXT’s employee population.  These include:

• Employment conditions
• Processes for reporting and resolving staff concerns and grievances
• Non-discriminatory hiring practices
• Employment screening (including work eligibility checks); and
• Appropriate workplace behaviour

Through our Positive Work Environment Policy (“The Policy”) all employees are responsible for creating a respectful environment and are required to identify and report workplace discrimination, violence and harassment if it occurs.  BOXT’s employees receive annual training on the Policy and are required to certify annually that they have read and complied with it.

BOXT also maintains an anonymous reporting hotline (“Hotline”) for its employees to anonymously report, among other things, any matters relating to suspected unethical, illegal, unsafe, or other unwanted behaviours. Modern slavery and human trafficking issues are reportable on this hotline.  The reporting hotline is managed by an independent third party and is accessible in multiple languages online and via a toll-free phone number 24/7.

Telephone: 800-603-2869 (must dial country access code first https://www.lighthouse-services.com/documentlink/International%20Toll-free%20Hotline%20Access%20Instructions.pdf

for access codes and dialling instructions) 

E-mail: [email protected] (must include company name with report)

Website: www.lighthouse-services.com/boxt

Based on the above, we consider that there is a low risk of modern slavery within our employee population.

Management of Modern Slavery Risks

1. Governance

We recognise that strong governance is essential to sustainable business operations and we aim to conduct our business according to the highest ethical and legal standards.  Our approach to addressing modern slavery is designed to be commensurate with the risks we face.  Key supporting policies and guidelines include, but not limited to:

Anti-Slavery and Human Trafficking Policy – This sets out BOXT’s procedures to identify and mitigate the risks of modern slavery and human trafficking within our business and supply chain, including anti-slavery training and risk assessments.

Code of Business Conduct and Ethics – Our code of business (the “code”) outlines our commitment to conducting business in an ethical and responsible manner, including by carrying out our activities in a manner that respects the protection of human rights.  Employees are required to certify annually that they have read and complied with the Code and the protocols incorporated therein.

Financial Crime Policies – These include our anti-bribery and corruption and anti-money laundering programs that are designed to prevent financial crime and the movement of money derived from crime (includes crimes relating to modern slavery).

Positive Work Environment Policy – This outlines our commitment to providing a workplace free of discrimination, violence and harassment and summarises the responsibilities of employees to understand (i) what constitutes workplace discrimination, violence and harassment; (ii) their obligations to maintain an environment where these behaviours are not tolerated; and (iii) how to report incidents following proper procedures.

Whistleblowing Policy - BOXT is committed to conducting business with honesty and integrity and staff are expected to maintain high standards. This Policy clearly sets out the expectations of reporting and responsibilities, and outlines whistleblowing procedures addressing how to raise a concern, confidentiality, as well as remediation, external disclosures and our zero tolerance for retaliation or malicious acts.

(Together, the “Policy Framework”) 

Our Policy Framework is reviewed and periodically updated, as necessary.

2. Training

All BOXT employees receive modern slavery training during the onboarding process and access ongoing training, as necessary. 

3. Risk Assessment

Risk Assessments are important to BOXT’s efforts to promote the eradication of modern slavery.  The risk-based approach enables BOXT to focus efforts where most required. Our Anti-Slavery and Human Trafficking Policy requires risk assessments are conducted annually to assess the nature and extent of exposure to modern slavery risks in our operations and supply chains.

4. Remediation

Where possible, we will seek to use our influence to resolve any identified concerns.

5. Whistleblowing Hotline

As detailed above, the Hotline is available for employees, Vendors and other parties to anonymously report modern slavery and human trafficking issues among other things.  The reporting hotline is managed by an independent third party and is accessible in multiple languages online and via a toll-free phone number 24/7.

6. Measure of effectiveness

BOXT acknowledges that modern slavery and human trafficking are possible risks within our operations and supply chain. BOXT undertakes various steps to address these risks in our business, including reviewing our policies and business practices to ensure they reflect our commitment to:

• Implementing and enforcing effective systems and controls designed to reduce the risk of modern slavery in our business and supply chains; and 
• Transparency through our disclosure obligations

We monitor and assess the effectiveness of our modern slavery program through:

• Regular engagement and feedback from key stakeholders, including through active promotion of our reporting Hotline.
• Operational risk and mitigation plan reporting to the Board of Directors and senior executives; and 
• Implementation and refinement of our vendor management and due diligence processes.

Reviewing our Statement

We will review our modern slavery statement annually and update it as necessary. We will also ensure that it is easily accessible to anyone who wishes to read it. This statement has been approved by the Board of Directors on behalf of BOXT Limited and is made pursuant to section 54(1) of the Modern Slavery Act 2015.

Last updated: 29th September 2023