Introduction

This statement is made by B2C2 Ltd (the “Firm” or “B2C2”), on behalf of itself and its subsidiaries, including but not limited to: B2C2 OTC Ltd, B2C2 Europe SARL, B2C2 France SaS, Woorton SaS,  B2C2 Japan Co Ltd, B2C2 Asia Pte Ltd, B2C2 Singapore Pte Ltd, B2C2 Overseas Ltd, B2C2 USA Inc and B2C2 Securities LLC (“B2C2”, “we”, “us” or “our”), pursuant to section 54 of the UK Modern Slavery Act 2015 (the “Act”) and equivalent legislation in other relevant jurisdictions. It outlines the steps taken to identify and mitigate the risk of modern slavery and human trafficking without our operations and supply chains.

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B2C2 is committed to operating responsibly and ethically. We recognise our obligation to combat modern slavery and are fully committed to preventing it within both our own business and across our supply network. This statement is shared with all employees and published on the B2C2 Website.

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Organisational Structure

B2C2 is a crypto-native liquidity provider,  established in 2015 and majority-owned by Japanese financial group SBI Holdings since 2020. The Firm operates independently, with headquarters in the UK and offices in the US, Luxembourg, France (Woorton), Singapore, Cayman Islands and Japan. B2C2 continues to prioritise  responsible corporate citizenship and considers environmental, social and governance issues. Working towards long term responsibility and sustainability continues to be a priority.

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Our Supply Chain

Given the nature of operations, we assess the risk of modern slavery within our supply chain to be low. The Firm's supply chain primarily consists of providing trading infrastructure, research, development, operations and treasury services to our affiliates. The Firm also utilises other suppliers of products and services on a customer basis to meet staff and business needs, such as professional services providers, software suppliers, cloud hosting providers, ICT (information and communications technology) providers and recruitment agencies.

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We maintain close oversight of third-party vendors and partners, favouring suppliers who share our values of human rights and ethical standards.

Internal Procedures

We have implemented  the following internal procedures to prevent modern slavery and human trafficking:

• All employees are expected to comply with the Staff Handbook relevant in their jurisdiction, the Vendor and Outsourcing Management Policy, Whistleblowing Policy, and other relevant policies.
• We have a robust recruitment and onboarding process with multiple checks built in to ensure all individuals employed by B2C2 have the right to work in the relevant country, are paid a fair salary in compliance with all rules and regulations, and are not subject to human trafficking or forced labour.
• Our supplier agreements mandate compliance with applicable anti-slavery and human trafficking laws.
• We conduct our business activities in the highest ethical and professional manner and we expect our suppliers to adhere to these same standards and principles.
• The terms we have in place with recruitment agencies require them to comply with all applicable anti-slavery and human trafficking laws, statutes and regulations.
• We follow a careful selection and due diligence process for vendors.
• As an office-based, technology-reliant firm, our laptops/desktops and key peripherals are sourced from accredited resellers and from reputable brands

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Responsibility

Responsibility for our anti-slavery program is allocated as follows:

• Statement Oversight: The Legal and Compliance Division (“LCD”) is responsible for putting the Statement in place.
• Vendor Due Diligence: The Business Management function is responsible for the Vendor and Outsourcing Management Policy and related framework, supported by each relevant function for the specific vendors that those functions engage, including appropriate due diligence on and oversight of vendors or suppliers.
• Investigations: Human Resource (“HR”), Risk and LCD are responsible for investigations in relation to known or suspected instances of slavery and human trafficking. LCD has overall responsibility for investigating vendor management issues and HR has overall responsibility for recruitment issues.
• Training: B2C2 employees undertake regular training on a variety of topics. Modern Slavery has been openly discussed and promoted by senior management in the firm. Modern Slavery awareness is provided to the firm periodically and this statement is sent to all employees.
  
  

Relevant Policies

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Whistleblowing policy We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, our Firm. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can email regulatory@b2c2.com or contact the independent whistleblowing charity Protect on (020) 3117 2520.  Additionally, employees may use our confidential disclosure form which is anonymous unless the employee elects to disclose their details by entering them into the form.
• Vendor and Outsourcing Management Policy - The Policy underscores the importance of adhering to the local laws and regulations, risk management practices, and effective and diligent vendor management. It outlines the procedures for identifying, understanding, quantifying, and mitigating risks associated with doing business with vendors.
• Employee expectations - we make it clear to employees the actions and behaviour expected of them when representing our Firm. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing supply chains.
• Recruitment Agencies - We use reputable employment agencies to source labour and always verify the practices of any new agency before accepting workers from that agency. 

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Awareness-raising Programme

We have raised awareness of modern slavery issues by providing awareness training in firmwide meetings and outlining the importance of all employees having awareness of the issues.

The awareness discussions cover:

• the basic principles of the Act;
• how employers can identify and prevent slavery and human trafficking; and
• what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within our Firm.

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Measuring Effectiveness

To monitor the effectiveness of the steps we are taking, we:

• Provide a Whistleblowing Policy and training to all staff and investigate all instances of whistleblowing;
• Conduct compliance testing;
• Conduct compliance surveillance of communications;
• Utilise our Internal Audit function and External Auditors;
• Conduct vendor oversight as outlined in the Policy 
• Have MI, KPIs and KRIs related to all aspects of our business; and
• Review and improve policies in line with our tiered policy framework.

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Approval and Signature 

This statement was reviewed by cross-functional stakeholders including representatives and leaders from our global HR, Legal, Risk, Compliance and Operations  teams, and directors from each B2C2 entity, where relevant.