HUMAN RIGHTS STATEMENT

Compliance

The UK’s Modern Slavery Act of 2015 requires businesses providing goods and services to publish an annual statement specifying the efforts the company has taken to ensure modern slavery and human trafficking are not taking place in its business or supply chain.

Symphony Communication Services, LLC is the leading markets’ infrastructure and technology platform where solutions are built or integrated to standardize, automate, and innovate financial services workflows. On June 24, 2021, Symphony acquired Cloud 9 Technologies, LLC, which offers voice trading services to the UK market through its subsidiary, Cloudnimbus Holdings Ltd. This statement applies to Symphony Communication Services UK Ltd. (10155995) and Cloudnimbus Holdings Ltd. (09820855), in respect of the fiscal period ending 31 December 2021.

Symphony is committed to acting ethically and with integrity in all our business relationships. Based upon the primary nature of our business, which provides an enterprise level software-as-a-service communication platform, Symphony has assessed the risk of modern slavery and human trafficking in our operations as low. Our core service offerings have a relatively limited supply chain that primarily consists of providers of Information Technology and professional services. However, Symphony is opposed to the trafficking of persons or use of any form of slavery and has taken steps to assess and manage that risk.

Symphony has a zero-tolerance policy towards forced or bonded labor. We ensure that all our terms of employment are voluntary and adhere to local laws with respect to minimum age requirements, wages, overtime, working hours, and benefits. Although it is for our business suppliers and partners to manage their own operations, we expect our suppliers and partners to align with our values and to conduct business and comply with all applicable laws. Further, Symphony fosters a culture of open and honest communication, where employees are encouraged to speak up and to raise any concerns of potential or actual ethical conduct breaches.

Symphony is committed to continually improving our efforts to identify, address and prevent modern slavery. Moving forward, we commit to: uplifting our ethics compliance procedures to facilitate reporting of alleged misconduct involving the company and any suppliers or partners; reviewing the policies and procedures for onboarding and ongoing due diligence of our suppliers and partners; and enhancing the training provided to staff responsible for procurement and relations with our business partners.

In conclusion, Symphony will continue to assess its business and supply chains to identify potential modern slavery risks and target those areas with policies, procedures, and trainings to ensure it maintains appropriate safeguards to mitigate those risks.

This statement has been approved by and signed for and on behalf of the Board of Directors of Symphony Communication Services UK Ltd. and Cloudnimbus Holdings Ltd.:

 

Corinna Mitchell
General Counsel

30 September 2022