Skip to content

Modern Slavery Statement

The UK Modern Slavery Act 2015 (the “Act”) requires organizations with a turnover of more than £36m to make a public statement on steps they are taking to identify and prevent modern slavery and human trafficking in their operations and supply chains.

otala.markets Ltd (“otala.markets”) has published its 1st Modern Slavery Statement, in accordance with section 54(1) of the Act in respect of our financial year from 1 January 2024 to 31 December 2024 (“FY24”).

About Us

otala.markets is an independent financial boutique specialised in issuing structured products, providing asset securitisation and investment technology solutions. Our teams of global industry experts focus on creating infinitely flexible, high quality financial solutions for our evolved clients with the highest level of commitment and care.

otala.markets is authorised and regulated by the Financial Conduct Authority (“FCA”) as an Investment Firm under the UK Financial Services and Markets Act (“FSMA”) and the EU 2nd Markets in Financial Instruments Directive (“MiFID2”) and underlying Regulations.

otala.markets is a Benchmark Administrator and is supervised by the Financial Conduct Authority.

The company’s head office is located in London, UK with business operations across the Europe.

otala.markets is controlled by a Board of Directors, including the Chairman who is a Non-Executive Director.

otala.markets is predominately involved in the provision of investment and benchmark administration services, as defined in the FSMA, MiFID2/Regulations and its regulatory licence permissions.

Definitions

otala.markets considers that modern slavery encompasses:

  • Human trafficking;
  • Forced work, through mental or physical threat;
  • Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
  • Being dehumanised, treated as a commodity or being bought or sold as property;
  • Being physically constrained or to have restriction placed on freedom of movement.

Our Commitment

otala.markets is committed to the principles of the Act and the abolition of modern slavery and human trafficking. Our actions around prevention of slavery and human trafficking aim to:

  • Ensuring slavery or human trafficking is not taking place in the company’s own business and supply chain; and
  • Exercising our influence over partners with whom otala.markets has business relationships, to encourage adoption of measures to prevent slavery and human trafficking.

As an equal opportunities employer, we’re committed to creating and ensuring a non-discriminatory and respectful working environment for our staff. We want all our staff to feel confident that they can expose wrongdoing without any risk to themselves. Our recruitment and people management processes are designed to ensure that all employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.

We do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.

Our Supply Chain

Due to the nature of otala.markets’ business, in our supply chain the risk of slavery and human trafficking is very limited because our service providers and counterparties are known, reputable, professional and/or regulated organizations.

The supply chain pertaining to the otala.markets’ business encompasses service providers that one would typically expect for an office-based financial services business, covering professional services, information technology, communications, building services/facilities, food, travel, office furniture, among other goods and services.

Our Policies

otala.markets is committed to preventing any form of slavery and human trafficking in its business and supply chains. The specific anti-slavery and human trafficking measures adopted by the company form part of its overarching Compliance, Risk and Governance frameworks, which are overseen by the Executive Committee, Risk & Compliance Committee and ultimately, by the Board of Directors.

This Statement and otala.markets’ internal policies have been approved by the Board of Directors.

Due Diligence and Responsible Procurement

otala.markets reviews its business and supply chains regularly to identify the main risk areas where slavery or human trafficking may exist. The due diligence exercise is typically focused on engaging with the company’s suppliers. Based on a risk-based approach, the company’s engagement has primarily focused on the main suppliers. For this purpose, the otala.markets has ranked supplier relationships based on various factors, such as, fees paid; suppliers’ operating sectors that present generally heightened risks of slavery or human trafficking. Over time the company will expand the due diligence scope to cover all suppliers.

otala.markets has a responsible procurement approach and engages with its suppliers on various risk factors. The company enhances its procurement and due diligence process with a requirement for the relevant suppliers to address modern slavery risks and, in the case of suppliers subject to the Act, confirm their compliance with the Act.

On a regular basis and in line with their risk rating (where applicable), the main suppliers are issued with request to refresh their due diligence profile with the company, including re-affirmation of their compliance with the Act to ensure that slavery and human trafficking are not taking place in their businesses. For the next reporting year, all suppliers will be subject to such a mandatory requirement.

For due diligence and procurement process, otala.markets obtains and reviews the publicly available information and utilises a specialist third-party provided database and tool to identify any reports and media coverage of key suppliers in respect of modern slavery. The third-party database and tool are used to monitor and screen all main suppliers on an on-going basis (watchlists), including for any allegations pertaining to slavery and human-trafficking risk.

Through this third-party screening and monitoring of the key suppliers, otala.marketsl becomes aware of any instances of slavery related allegations in our supply chain. Should there be any such instance, otala.markets will raise the issue with the relevant supplier for explanations.  

Training and Awareness

otala.markets provides mandatory training and supporting information to all employees on slavery and human trafficking, and on the implications of the Act for the company’s business going forward, as part of the annual training program.

Awareness-raising materials, which are prepared by the specialist external vendor, are provided to all personnel of the company.

otala.markets’ primary objective in providing training and information is to ensure that all employees have sufficient knowledge and understanding to identify potential slavery and human trafficking risk factors, and to highlight the steps taken and planned by the company to address these risks.

otala.markets’ is committed to continuing to take positive steps to prevent slavery and human trafficking in its business and supply chains. As such, we will continue to embed the principles through:

  • Continuous provision of awareness and training to all employees on the Act and reminding them of the appropriate actions to take if they suspect a case of slavery or human trafficking
  • Ensuring that all personnel involved in a procurement and due diligence activity are aware of and follow modern slavery procurement guidance on GOV.UK
  • Ensuring that consideration of the modern slavery risks and prevention form part of otala.markets’ internal risk management framework and risk assessment processes
  • Ensuring that otala.markets’ contractual terms and conditions include references to prohibition and prevention of modern slavery and human trafficking
  • Encouraging actions to embed a zero-tolerance policy towards modern slavery
  • Ensuring that all personnel involved in a recruitment of new employees receive training on modern slavery and ethical employment practices.

Statement Approval

This Statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and is otala.markets’ slavery and human trafficking statement for the financial year ending 31 December 2023.

This Statement is approved by the Board of Directors on 01 March 2024.

Signed on behalf of the Board of Directors:

Mr. Babu Sivanithy

Managing Director