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Introduction

This statement is made by B2C2 Ltd (the “Firm” or “B2C2”) on behalf of itself and relevant B2C2 entities that are subject to the requirements of section 54 of the UK Modern Slavery Act 2015 (the ‘Act’). This statement sets out B2C2's actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2022 to 31 Mar 2023.

As part of the financial services industry, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking. The Firm is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

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Organisational Structure

This statement covers the activities of B2C2 Ltd, a crypto-native liquidity provider for institutions. Founded in 2015 and majority owned by Japanese financial group SBI Holdings since 2020, B2C2 remains a standalone company. It is headquartered in the UK, with offices in the US and Japan. B2C2 aims to be a responsible corporate citizen and considers environmental, social and governance issues. Working towards long term responsibility and sustainability continues to be a priority for the coming year. 

We currently operate in the following countries: UK, US, Japan and Cayman Islands. The subsidiaries of B2C2 Ltd. include but are not limited to:

• B2C2 Japan Co, Ltd. 
• B2C2 OTC Ltd.
• B2C2 Overseas Ltd.
• B2C2 Securities LLC 
• B2C2 USA Inc.

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Our Supply Chain

Due to the nature of services B2C2 offers, we believe that the overall risk of facilitation of modern slavery and human trafficking in our business or amongst our suppliers is 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.

Internal Procedures

The following are internal procedures to prevent modern slavery and human trafficking from taking place in our Firm or supply chains:

• All employees are expected to comply with the HR Staff Handbook, the Compliance Manual, the 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. 
• 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 initiatives is as follows:

• Statement: The COO is responsible for putting the Statement in place. 
• Due diligence: The operations department is responsible for ensuring due diligence is performed on vendors or suppliers.
• Investigations: HR, Risk, Legal and Compliance are responsible for investigations in relation to known or suspected instances of slavery and human trafficking. The COO 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 was provided to the whole firm in Q1 2023.
  
  

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.
• Employee Staff Handbook - Our Handbook makes 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 its supply chain.
• 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. ‍
• Compliance Manual - The Compliance Manual sets out key rules, regulations and regulatory principles as well as standards of employee conduct that the firm expects staff to adhere to.

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Performance Indicators

We have reviewed our key performance indicators (KPIs). As a result, we:

• require all staff to complete training on modern slavery on an annual basis;
• require all staff to provide their ID for verification prior to commencing employment; and
• shall complete a risk-based review of our existing supply chains whereby we shall evaluate existing suppliers by the end of the financial year.

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Awareness-raising Programme

We require all staff within our Firm to attend training on modern slavery. As well as training staff, we have raised awareness of modern slavery issues by discussing the matter 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.