Modern Slavery and Human Trafficking Statement - Dare

Modern Slavery and Human Trafficking Statement


This statement is made on behalf of Dare International Limited and its subsidiaries (together, the "Firm")
pursuant to section 54(1) of the Modern Slavery Act 2015 (the "Act") and sets out the steps
that the Firm has taken during the financial year ending 31 December 2022 to combat modern
slavery and human trafficking in its business and supply chains.

The Firm recognises the importance of tackling modern slavery and human trafficking. It is
committed to taking appropriate steps to ensure that modern slavery and human trafficking
does not occur within any part of the Firm's business or any of its supply chains.


The Firm is a private limited company incorporated in England and Wales, with its head office
and operations in the United Kingdom. The Firm actively trades the assets of its group company,
Dare Global Limited (a private limited company incorporated in the Cayman Islands), and
realises trading opportunities by applying new technologies and quantitative models on a
variety of financial markets.

The Firm employs over 180 professional employees in the United Kingdom and is committed to
the welfare of all staff, including in terms of pay, working hours, environment, health and safety,
and wellbeing. The Firm does not tolerate violations of basic human rights or employment
practices, by or against any staff, or within its supply chain.

As a professional service provider, the Firm does not consider its business to operate within a key
risk sector as its staff work in roles that are primarily office based and/or generally require
specialist qualifications. Therefore, the Firm assesses the risk of modern slavery and human
trafficking within its business to be low.

Supply chain

Due to the nature of the Firm's business, the Firm has a relatively simple supply chain model.
The Firm's supply chain primarily includes exchanges, trading venues, brokers, market data
providers and industry professionals, most of which are subject to industry regulations. The Firm
also engages other miscellaneous suppliers as necessary to maintain the normal day-to-day
operations of the Frim's business and to support its core business, such as cleaners, caterers and
maintenance workers.

The Firm considers these services to generally present a low risk of modern slavery and human
trafficking. However, the Firm recognises the need to continue to work with its suppliers to tackle
modern slavery in their own supply chains.

Relevant policies, training and due diligence

The Firm has policies and training programs in place that underpin its commitment to ensure
that there is no modern slavery or human trafficking in its supply chain or in any part of its

As part of the Firm's onboarding process, new employees must return a signed copy of the
Firm's Health and Safety Policy, which sets out the commitment and approach to
protecting the health and safety of its staff and all those affected by its business activities.

New employees and professional contractors are also required to attend an induction in relation
to the Firm's Compliance Manual, which makes it clear that the Firm operates in a highly
regulated industry and that it is essential that the Firm and its workers comply with all legal and
regulatory requirements.

The Compliance Manual also includes the Firm's policies relating to:

  • whistleblowing, which encourages employees to raise concerns about the Firm, its business,
    other employees and counterparties; and
  • anti-money laundering and Know Your Customer checks with respect to counterparties.

Current copies of all Firm policies are accessible to employees via the Firm's intranet platforms.
The Firm frequently reviews and updates its policies.

The Firm also provides its employees with the following:

  • annual 'dignity at work' training, which seeks to prevent the occurrence of discrimination,
    harassment, bullying or victimisation in the workplace (and which the Firm proposes to also
    publish as a formal policy); and
  • access to an employee assistance program (provided by an independent third party
    company) that can be used by the Firm's employees for free and confidential advice in
    relation to workplace concerns or issues. 

To assess the risks within its supply chain, the Firm carries out diligence on its material suppliers
by making due enquiries of prospective suppliers, including in accordance with the Compliance
Manual and, in respect of IT or software vendors, a vendor risk assessment questionnaire. The
Firm also adopts internal control and governance procedures with respect to approving
financial transactions and signing contracts with suppliers, ensuring that contracts cannot be
entered into without authorisation by a suitably senior and qualified member of staff.

Looking ahead

The Firm remains committed to maintaining strong policies and procedures to identify and
prevent modern slavery and human trafficking in its business and supply chains. It will continue
to review and enhance these policies and procedures over the course of the next financial year.


This Statement has been reviewed and approved by the Firm's Board of Directors for the year
ending 31 December 2022.

Ayman Rahman
Chief Executive Officer
Dare International Limited

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