Our Carbon Emissions & Energy Consumption

      Our carbon reporting is aligned with the Streamlined Energy and Carbon Reporting (SECR) regulations. We also disclose via the CDP (Carbon Disclosure Project) and the GRI sections 302-1, 305-1, and 305-2.  The Executive Owner of these areas is Martin Ryan, Group Chief Operating Officer.

      Carbon Emissions

       

      Current reporting year
      1 Jan 2021 – 31 Dec 2021

      Comparison reporting year
      1 Jan 2020 – 31 Dec 2020

      Emission Source

      UK

      Global (Excluding UK)

      UK

      Global (Excluding UK)

      Emissions from activities for which the Company own or control including combustion of fuel and operation of facilities (Scope 1) (tCO2e)

      700

      221

      475

      297

      Emissions from purchase of electricity, heat, steam and cooling purchased for own use (Scope 2) (tCO2e)

      1,499

      7,813

      4,421

      4,107

      Emissions from business travel via air and taxi (Scope 3) (tCO2e)

      160

      687

      300

      477

      Total gross Scope 1, Scope 2 and Scope 3 emissions (tCO2e)

      2,359

      8,721

      5,196

      4,880


      Energy Consumption

       

      Current reporting year
      1 Jan 2021 – 31 Dec 2021

      Comparison reporting year
      1 Jan 2020 – 31 Dec 2020

      Energy consumption used to calculate Scope 1 emissions (kWh)

      3,823,486

      1,205,892

      2,584,497

      1,480,384

      Energy consumption used to calculate Scope 2 emissions (kWh)

      7,059,627

       18,925,687

      5,439,505

      4,855,965

      Energy consumption used to calculate Scope 3 emissions (kWh)

      620,610

      2,862,517

      1,157,271

      1,866,947

      Total energy consumption based on the above (kWh)

      11,503,722

      22,994,096

      9,181,274

      8,203,296

      Intensity ratio: tCO2e (gross Scope 1, 2 + 3) per employee

      2.05

      2.05

      Methodology Anthesis has calculated the above greenhouse gas emissions estimates to cover all material sources of emissions for which the Group is responsible. The methodology used was that of the ‘Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (revised edition, 2015)’. Responsibility for emissions sources was determined using the operational approach. All emission sources required under the ‘Companies, Partnerships and Groups (Accounts and non-financial reporting) Regulations 2016‘ are included.

      Managing Our Energy Use

      We are working with external experts to develop clearly defined greenhouse gas emission reduction targets and action plans in line with the emission reductions required to limit the global temperature increase to well below 2°C compared to pre-industrial levels.

      Managing Our Other Resource Use (Water, Paper, Plastics, and Waste Management)

      Across our global offices, we take steps to minimize the environmental impact of our operations. There are paper, plastic, and metal recycling stations throughout our offices. We use ‘follow-me’ printer systems that require ID scans at printing stations to avoid wasting paper.

      Supply chain management

      We make every effort to manage our supply chains responsibly and hold our partners to high standards. We cultivate strong relationships with our key suppliers, managing risks and encouraging sustainability using a structured framework. Our Procurement team is working on developing new guidelines to ensure our IT equipment, office supplies, and other purchases are sustainably sourced according to certified schemes.

      Task Force on Climate-related Financial Disclosures (TCFD)

      The Board and ExCo have recognised the importance of climate-change and in line with Task Force on Climate-Related Financial Disclosures (TCFD’s) recommendations and recommended disclosures have made the following disclosures below in regard to Governance, Strategy, Risk Management and Metrics and Targets. We recognise that we are on the first steps to becoming a zero-carbon organisation and we remain committed to disclosing the risks and opportunities climate change poses to our business. We support increased transparency through TCFD as we acknowledge that this would also improve market efficiency and economic resilience in the markets where we operate.

      In 2021, as part of our overall risk management and in anticipation of TCFD requirements, we have made progress in the all four key areas. This included establishing oversight at Board level that defined roles and responsibilities; beginning a strategic impact analysis as to how climate change would impact our business; incorporated ESG requirements into the Group’s ERMF that includes risk identification and evaluation as well as into future scenario testing; and delivered on our sustainability disclosures that are included in this annual report.

      TP ICAP plc has complied with the requirements of Listing Rules 9.8.6R by including climate-related financial disclosures consistent with the TCFD recommendations and recommended disclosures except for the following matters:

      • Completing our climate change impact analysis on TP ICAP Strategy; and
      • Establishing further appropriate zero-carbon metrics and targets in addition to the Environmental disclosure shared in this annual report.

      The Group Head of Sustainability was appointed in June 2021 and focused on advancing the appropriate tone from the top and governance as a priority. A meaningful climate change impact analysis and setting the appropriate metrics requires an understanding of the business operations globally and input from across the Group. This requires time to gather as this type of management information has not previously been available. These remaining requirements are expected to have been completed by Q1 2023.

      TCFD recommended disclosures

      TP ICAP approach in 2021

      Governance

      a. Describe the board’s oversight of climate-related risks and opportunities.

      The Board has oversight of the Group’s Sustainability Framework and Strategy, including TP ICAP’s climate-related risks and opportunities. The Group CEO sponsors the Group Sustainability Strategy at Board level.

      The Group appointed a new Group Head of Sustainability, who reports to the Board on environmental matters as part of our overall Environmental, Social, and Governance (ESG) reporting.

      b. Describe management’s role in assessing and managing climate-related risks and opportunities.

      The Executive Committee (‘ExCo’) is responsible for setting the Group’s targets in order to manage and to improve our environmental performance. ExCo established the Group ESG Forum to provide oversight and advice.

      The ESG Forum reports into the ExCo and its membership includes the Chief of Staff (Chair), Group Head of Marketing and Communications; Group Head of Sustainability; Group Head of HR; Group Chief Operating Officer; Legal/Governance, Risk, Investor Relations and Finance representatives.

      In relation to ESG strategy, the ESG Forum has Group-wide responsibility for:

      • Overseeing climate-related risks and opportunities to support our strategic decision-making.
      • Implementing policies, delivery, communications, and disclosures.
      • Tracking the emerging risks associated with climate change, including the risks arising from climate change itself and from the transition to a zero-carbon economy.
      • Monitoring regulatory developments to ensure we remain compliant.

      Strategy

      a. Describe the climate-related risks and opportunities the organisation has identified over the short, medium, and long term.

      Our business operates in markets located all over the world. This widens the scope of the risks that we face, but does limit the risk of a physical single event.

      We are in the early stages of evaluating the potential impact of climate-related risk and how physical and transition risk may impact our business.

      We have already identified that there are several risks that may hinder our transition to a low carbon future. In particular, these are certain types of products that we broker, broader market expectations, and the changing regulatory landscape.

      We will continue to review and update our analysis of the climate-related risks and opportunities our organisation will face, and report more specific short, medium, and long-term risks in next year’s Annual Report.

      b. Describe the impact of climate-related risks and opportunities on the organisation’s businesses, strategy, and financial planning.

      We aim to be the Broker for the Transition to an inclusive, low-carbon future. Tackling climate change is perhaps the greatest challenge of our time, so we are leveraging our unique capabilities in market infrastructure, client connectivity, liquidity, price discovery, and data solutions to create new markets and products. As the world turns from carbon-intensive practices to sustainable alternatives, we want to do our part to accelerate this transition.

      In 2021 we established the Sustainable Finance Working Group (SFWG), which includes senior leadership from the Group’s business divisions, to identify commercial sustainability-aligned opportunities. Part of the SFWG’s mandate is to identify ways the Group can use its platform to develop products and services that help our clients make the transition to a sustainable future.

      c. Describe the resilience of the organisation’s strategy, taking into consideration different climate-related scenarios, including a 2°C or lower scenario.

      The Group actively evaluates its strategy under a number of scenarios, including a transition to a low-carbon economy. We hope to have more clarity as to the resiliency of the Group’s strategy in future updates, and once our impact analysis is complete.

      Risk management

      a. Describe the organisation’s processes for identifying and assessing climate-related risks.

      We consider climate-related risks as part of our enterprise risk management framework (‘ERMF’). This includes existing and emerging regulatory requirements that could impact the Group’s business.

      The ERMF has been updated to include ESG as a separate part of its taxonomy, and we continue to review how best to evolve our ERMF to appropriately reflect this risk. Our current business-as-usual risk management processes include risk identification, evaluation and assessment.

      b. Describe the organisation’s processes for managing climate-related risks.

      The Group Head of Sustainability reports to the Board and ExCo on major climate-related risk areas, including making recommendations on how to mitigate, transfer, accept or control those risks. We also work with a third-party expert to identify the carbon emissions stemming from our operations and explore ways to minimise them.


      This also feeds into the Group’s broader risk management reporting to provide the Board and senior management context for the prioritisation and identification of any trends.

      c. Describe how processes for identifying, assessing, and managing climate-related risks are integrated into the organisation’s overall risk management.

      In addition to the Board’s initial actions, we have incorporated climate-related risks into our ERMF. We have started by incorporating TCFD and climate-related risks with its own unique part of our risk taxonomy and risk management standards. We are looking to evolve this across the risk types as we better understand the impacts of climate change.

      We have already included climate-related risks as part of our annual risk identification, evaluation assessment process, as well as incorporating new controls in early 2022. Once the controls have been fully implemented, they will be assessed as part of our standard risk management processes.

      Metrics and targets

      a. Disclose the metrics used by the organisation to assess climate-related risks and opportunities in line with its strategy and risk management process.

      Over the coming year, we plan to assess the specific targets and metrics that we consider to be most relevant for our business in direct response to climate-related risks and opportunities.

      Our business divisions are developing approaches to gain more exposure to the low-carbon transition economy.

      b. Disclose Scope 1, Scope 2, and, if appropriate, Scope 3 greenhouse gas (GHG) emissions, and the related risks. 

      Please see our Environmental Disclosures above for these disclosures.

      c. Describe the targets used by the organisation to manage climate-related risks and opportunities and performance against targets.

      The Group is evaluating targets tied to reducing its carbon emissions. In 2022, we will continue our efforts to develop methodologies that enable more robust and transparent disclosure of climate metrics connected to climate risk management.

        Our social reporting is aligned with the SASB Investment Banking & Brokerage Sustainable Accounting Standard (SASB FN-IB-330a.1) and the GRI sections 102-8, 201-1, 401-1, and 404-1. The Executive Owner of these areas is Sue Maple, Group Head of Human Resources.

        Employee Diversity and Inclusion

        Percentage of gender representation by Category

         

        Current Reporting Year
        1 Jan 2021 - 31 Jan 2021

        Comparison Reporting Year
        1 Jan 2020 - 31 Dec 2020

        Category

        Female

        Male

        Female

        Male

        Executive Management

        20%

        80%

        24%

        76%

        Non Executive Management

        27%

        73%

        26%

        74%

        Professionals

        21%

        79%

        18%

        82%

        All other employees

        25%

        75%

        24%

        76%

        US-only percentage racial/ethnic group

         

        Current Reporting Year
        1 Jan 2021 - 31 Jan 2021

        Category

        Asian

        Black /African American

        Hispanic/Latino

        White

        Other

        Executive Management

        50%

        0

        0

        50%

        0%

        Non Executive Management

        7%

        0

        7%

        86%

        0%

        Professionals

        8%

        3%

        4%

        82%

        4%

        All other employees

        11%

        4%

        8%

        71%

        6%

         

        Comparison Reporting Year
        1 Jan 2020 - 31 Jan 2020

        Category

        Asian

        Black /African American

        Hispanic/Latino

        White

        Other

        Executive Management

        50%

        0

        0

        50%

        0%

        Non Executive Management

        4%

        0

        8%

        88%

        0%

        Professionals

        7%

        2%

        6%

        82%

        3%

        All other employees

        9%

        4%

        7%

        69%

        11%

        Employee Turnover and New Hires

         

        Current Reporting Year
        1 Jan 2021 - 31 Jan 2021

        Comparison Reporting Year
        1 Jan 2020 - 31 Dec 2020

        Gender

        Female

        Male

        Female

        Male

        Turnover

        228(22%)

        601(59%)

        197(30%)

        457(70%)

        New Hire

        297(26%)

        630(64%)

        195(27%)

        522(73%)

         

        Current Reporting Year
        1 Jan 2021 - 31 Jan 2021

        Comparison Reporting Year
        1 Jan 2020 - 31 Dec 2020

        Age Group

        <30

        30-50

        50+

        <30

        30-50

        50+

        Turnover

        197(19%)

        439(43%)

        191(19%)

        141(22%)

        344(53%)

        165(25%)

        New Hire

        321(32%)

        500(51%)

        98(10%)

        218(30%)

        391(54%)

        103(14%)

         

        Current Reporting Year
        1 Jan 2021 - 31 Jan 2021

        Comparison Reporting Year
        1 Jan 2020 - 31 Dec 2020

        Region

        APAC

        EMEA

        Americas

        APAC

        EMEA

        Americas

        Turnover

        194(19%)

        485(47%)

        344(34%)

        153(23%)

        359(55%)

        142(22%)

        New Hire

        256(26%)

        498(50%)

        236(24%)

        149(21%)

        451(63%)

        118(16%)

         

        Share of Temporary Staff

         

        Current Reporting Year
        1 Jan 2021 - 31 Jan 2021

        Comparison Reporting Year
        1 Jan 2020 - 31 Dec 2020

        Employment Contract By Gender

        Female

        Male

        Female

        Male

        Permanent

        1,293(24%)

        4,088(76%)

        1,136(23%)

        3,844(77%)

        Temporary

        47(6%)

        87(12%)

        31(6%)

        77(15%)

        Employment Type By Gender

        Female

        Male

        Female

        Male

        Full-time

        1,245(23%)

        4,060(76%)

        1,083(22%)

        3,811(78%)

        Part Time

        48(62%)

        28(36%)

        53(61%)

        33(38%)

         

        Current Reporting Year
        1 Jan 2021 - 31 Jan 2021

        Comparison Reporting Year
        1 Jan 2020 - 31 Dec 2020

        Employment Contract By Region

        APAC

        EMEA

        Americas

        APAC

        EMEA

        Americas

        Permanent

        1,163(22%)

        2,563(47%)

        1,677(31%)

        1,044(21%)

        2,422(49%)

        1,515(30%)

        Temporary

        29(4%)

        515(70%)

        187(26%)

        26(5%)

        391(78%)

        85(17%)

         

        Employee Training Hours
         

        Current reporting year
        1 Jan 2021 – 31 Dec 2021

        Comparison reporting year
        1 Jan 2020 – 31 Dec 2020

        Average training hours per employee by gender

        4.59

        0.67

        Charitable Contributions

        Current Reporting Year
        1 Jan 2021 - 31 Jan 2021

        Comparison Reporting Year
        1 Jan 2020 - 31 Dec 2020

        £3.6million

        £3.6million

        • Tax and other social payments

          The Group Tax Strategy explains that the Group is committed to complying with tax laws in a responsible manner and to having open and constructive relationships with tax authorities wherever we operate, and that the Group’s tax risk appetite is low. The Group made payments to tax authorities for 2020 of £525m (2019: £507m), comprising corporation tax, premises taxes, employer’s social security payments, income taxes and social security paid on behalf of employees in the UK and the US (the main jurisdictions in which it operates), and VAT/sales taxes borne and collected. In addition, the Group makes further tax payments to the tax authorities in other tax jurisdictions in which it operates.

        • Equality, Diversity, and Discrimination Commitment
          • 1.1 Our commitment
            • 1.1.1. The TP ICAP Group is committed to promoting Equality and Diversity and encouraging a culture that actively values difference. It is recognised that employees from different backgrounds and experiences can bring valuable insights to the work environment and enhance the way we work. TP ICAP aims to create a positive, cohesive and inclusive culture, where diversity is valued, respected and built upon. The objective is to recruit and retain a diverse workforce that reflects the global markets in which we work.
            • 1.1.2. TP ICAP is committed to ensuring that it does not directly or indirectly discriminate against Employees, ex-Employees, or candidates on the basis of any Protected Characteristics actual, perceptive, or associative or through Personal Relationships. It will not tolerate any unlawful discrimination by its Employees. Nor will it tolerate any favouritism based on Personal Relationships (also known as Anti Nepotism).
            • 1.1.4. TP ICAP is also committed to ensuring that the backgrounds, beliefs and cultures of all its Employees are respected and to ensuring that the working environment is free from discrimination, harassment, bullying or any other conduct which causes an Employee’s suffering. The Group also is committed to encouraging diversity amongst its current workforce and candidates.
            • 1.1.5. TP ICAP operates a number of controls to protect employees from discrimination:
              • The Group recognises that Employees, ex-Employees or candidates who are subjected to discrimination or harassment and bullying are vulnerable and may be reluctant or afraid to complain. The Group encourages any Employee, ex-Employee or candidate who believes that they are or have been subjected to any form of discrimination, harassment or bullying to report this to the local or regional HR function (for Employees, in accordance with the local Grievance Policy) .
              • Any Employee who observes conduct which they believe, in good faith, would reasonably be regarded as discrimination or harassment or bullying, are similarly encouraged to report it to their local or regional HR function.
              • The Group will provide appropriate training, development and support to those of its Employees involved in line manager activities
            • 1.1.6. In addition to formal controls and processes TP ICAP is also committed to promoting diversity and inclusion across the company and has developed an employee-led networking forum called “connect” which is tasked with promoting and celebrating diversity across the company including hosting events, co-ordinating training and development and networking to ensure any employee, from any background feels supported in the working environment.
              As another step forward in promoting diversity we will in 2018 appoint a Diversity Champion from our Executive management committee to act as the senior sponsor for diversity and inclusion in our business.
               
        • Employee Health and Safety
          Health and safety are critically important to TP ICAP. We are committed to protecting the health and safety of our colleagues, customers, suppliers, and any visitors to our offices. We recognize our duty to protect people from the risk of harm arising from the day to day activities in our business, and so we provide and maintain a safe working environment that protects both physical and mental wellbeing. We are in the process of identifying and developing a health and safety management system to maintain the appropriate controls across our offices.
           
        • Gender Pay Gap Report

              Gender Pay Gap Report 2021     

        • Human Rights and Freedom of Association Commitment
          We continue to support the UN Guiding Principles for Human Rights and recognise human trafficking and forced labour exists in both developed and developing economies and across sectors. Therefore, we are committed to taking steps to combat the risk of any form of modern slavery from occurring in our business or supply chain.
           
          • 1.1 Our commitment
            • 1.1.1. TP ICAP group supports fundamental principles of human rights across all our lines of business and in each region of the world in which we operate. TP ICAP’s respect for the protection and preservation of human rights is guided by the principles set forth in the United Nations Universal Declaration of Human Rights. In addition, we support the UN Guiding Principles on Business and Human Rights. This includes implementing our obligations. We have a defined set of values that underpin everything we do. We are known in the market for our honesty, integrity and excellence in the provision of service to our clients. Above all else, we respect our clients and each other, without bias.
            • 1.1.2. TP ICAP complies with applicable international and local legal requirements in the countries in which we operate.
            • 1.1.3. TP ICAP also looks to promote best practice through its supply chain and uses the UK’s Modern Slavery Act as a basis to help hold our suppliers accountable through regular checks and attestations in relation to Human Rights (see our Procurement and Modern Slavery statement).
            • 1.1.4. TP ICAP is committed to promoting a responsible employee environment respecting the human rights of our employees through our internal employment policies and practices. As part of our broad effort to ensure that respect for human rights is integrated into the business of the firm, TP ICAP has adopted policies and procedures designed to ensure compliance with legal requirements and which seek to prevent our products and services from being used for improper purposes. Such policies and procedures include those contained in our Code of Conduct, our Anti-Corruption, Anti-Money Laundering, Anti-Bribery, and Know Your Customer and counter-terror financing policies.
            • 1.1.5. TP ICAP is dedicated to exemplifying good corporate citizenship through our commitment to respecting human rights and through our broader commitment to corporate responsibility generally.
               
        • Procurement and Modern Slavery Commitment
          • 1.1 With over 7000 companies from over 26 countries supplying TP ICAP we take the sustainability of our
            • 1.1.1 supply chain and procurement exceptionally seriously. We apply a set of standards to our suppliers through our Supplier Code of Conduct. In order to do business with TP ICAP, our suppliers must accept responsibility to be held accountable to our Supplier Code of Conduct. Any new supplier who is being on boarded must attest that they meet those standards. Where suppliers fail to meet our expectations, we work to remediate gaps.
          • 1.2. Procurement
            • 1.2.1. We take the sustainability of our supply chain and procurement exceptionally seriously, and in 2017 implemented a number of initiatives that support this including:
              • Printing reduction via secure login and print management to reduce paper wastage;
              • Introducing Corporate Uber to help us track our CO2 usage and a new global travel provider to give us better intelligence on our Co2 usage;
              • Stopping the supply and usage of 14,500 plastic bottled water per week in the UK or 755,000 bottles a year in our London offices;
              • Providing a new agreement with Equinix for TPICAP’s core London Data Centre using the power supply from the Slough Heat & Power renewable energy station, which generates hot water and electricity by burning wood chips and fibre cubes made from used paper and cardboard. In addition to investing in more cloud- hosted products to reduce our global data centre foot print and power consumption including Icelandic Data Clouds);
              • Conducting a top 10 vendor assessment every year, including monitoring their CO2 data, as well as modern slavery practices, and
              • On-boarding processes for new suppliers, to assess the environmental impacts of their operations.
              • We continually look to improve our procurement processes to ensure that we are sector-leading in our approach and eliminating risk and improving the communities in which we operate.
          • 1.3. Modern slavery
            • 1.3.1. We take our obligations under the Modern Slavery Act (UK) extremely seriously. Any new supplier needs to declare that they strictly adhere to this Act. In 2017 we conducted an initial analysis of our top 30 direct suppliers concluding that they are all located in the US and EMEA and are, on balance, viewed as low risk. Many of our suppliers have comprehensive policies related to modern slavery.
              As a first step towards gaining a better understanding of our supply chain, we wrote to our top 30 suppliers, communicating our principles for modern slavery and asking for information about their policies and processes for tackling forced labour and human trafficking.
              To raise awareness of the risks of modern slavery and human trafficking in our business and in our supply chains, we provided specific modern slavery training to all employees who work directly with our suppliers in 2017.
              Finally, we introduced new targeted spot checks across our supply chain, performing credit checks, checking delivery against contract and physical location checks to identify suppliers who are vulnerable and most at risk of employing forced labour or slavery. In 2018 we will launch a new Code of Conduct for our suppliers, including clear processes and obligations in relation to Modern Slavery. We will also communicate more widely through our global intranet, our Modern Slavery principles to all employees to ensure that employees at all levels in our business understand our obligations and duties on this issue. We will continue to conduct spot checks and on board new suppliers to our high standards and will look to introduce metrics to measure our performance in this area.
               
        • Modern Slavery and Human Trafficking Statement
          This statement sets out the steps we have taken in the last financial year to prevent modern slavery and human trafficking from taking place in our business and supply chain.
          As a world-leading provider of market infrastructure, across a portfolio of brands in over 30 countries, TP ICAP takes its obligations under the Modern Slavery Act very seriously.
          We recognise human trafficking and forced labour exists in both developed and developing economies and across sectors. Therefore, we are committed to taking steps to combat the risk of any form of modern slavery from occurring our business or supply chain.
          We have made further progress over the past year, in relation to our purchasing policies, supplier risk management and the training of colleagues. In 2021, we will continue to build on what we have learnt, increase our awareness of areas of high risk and deepen understanding of modern slavery across the business.
           
        • Our business and supply chain
          TP ICAP is the world’s largest interdealer broker, providing professional intermediary services to match buyers and sellers of different financial, energy and commodities products.
          We are headquartered in London and employ c. 4,800 people globally. Further details of our structure and operations can be found in our 2019 Annual Report.
          As a global company, we rely on over 4000 suppliers, the majority of which are leading global providers of IT, telecoms, market data and professional services, located in the UK, US and Europe.
           
        • Impact of the COVID-19 Pandemic
          Whilst TP ICAP has continued to monitor the risk of modern slavery in our operations and supply chains, especially during these extraordinary times, coronavirus-related staffing pressures related to the need to prioritise supply chain continuity has caused a 6-month delay in the publication of this 2020 modern slavery statement.
          We had previously identified Travel & Entertainment as high-risk sectors in our supply chain in relation to modern slavery, but with virtually no activity in this area due to the COVID-19 pandemic restrictions, this risk has reduced significantly during 2020.
           
        • Our policies
          We are committed to operating in accordance with the International Bill of Human Rights and we fully support the UN Guiding Principles and other internationally accepted standards, including the International Labour Organisation Declaration on Fundamental Principles and Rights at Work.
          These commitments are reflected in TP ICAP's Group-wide policies, which set the standard of expected business behaviour for all employees. Relevant policies include:
          Our employee handbook which aims to foster a workplace environment that is fair, open and respectful, and one that promotes and protects the rights and dignity of all employees
          Our Purchasing Policy which sets out internal requirements for buying goods and services
          Our Corporate Social Responsibility Policy which covers issues relating to human rights, equal opportunities, employee development, health, safety, and welfare
          Our Whistle blowing Policy which encourages staff to report any concerns about illegal activity
          We keep these policies under review and - where relevant - we are strengthening them to include direct references to Modern Slavery and related issues. For example, we recently updated our key third-party supplier governance controls to ensure we have sought the relevant assurances from our supply chain partners in relation to modern slavery and have the frameworks in place to monitor these assurances.
           
        • Governance
          Our Modern Slavery and Human Trafficking Statement and our Supplier Code of Conduct are the responsibility of the Procurement Team and the Group Chief Operating Officer and will be updated and reported to the Group Risk, Culture and Conduct Committee ("GRCCC") on an annual basis. This reporting will then go to the plc Board, for sign-off by the Group CEO and Group CFO.
           
        • Assessing and managing risk
          We rely on our supply chain to provide professional services across the world, and we recognise that certain services, goods and markets are more exposed to modern slavery risk. TP ICAP has therefore re-assessed the way in which third party risks are identified and how suppliers are contracted and managed throughout.

          During 2020 we have revamped our Procurement governance controls, strengthening the initial assessment and ongoing monitoring across all areas of supply chain risk, including modern slavery. These updates include:
          • Introduction of a tiering process to identify high risk suppliers or supply chains, including modern slavery risks
          • Enhanced governance surrounding modern slavery checks and controls during supplier onboarding based on the risk tiering
          • Inclusion of a check for suitable contractual provisions covering modern slavery, where appropriate, during contract approval governance
          • Ongoing monitoring, using an intelligent risk monitoring application, to confirm there have been no law enforcement actions taken against any TP ICAP supplier in relation to known instances of modern slavery
        • Training & awareness
          Throughout 2020 we have been regularly communicating the changes to the Procurement governance controls, including the aspects in relation to modern slavery. We have also been monitoring non-compliance with these governance controls and taking the necessary steps where we identify instances of policy breach. We can report that we did not identify any policy breaches in relation to modern slavery during 2020.

          Next steps in 2021
          We will continue to raise awareness of modern slavery risks among colleagues and suppliers, plus we would like to add modern slavery compliance to our Risk MI framework, an action that was deferred during 2020. 

          This statement sets out the steps we have taken in the last financial year to prevent modern slavery and human trafficking from taking place in our business and supply chain. It is made pursuant to section 54 (1) of the Modern Slavery Act 2015, for the financial year ending December 31st 2020, as approved by the Board on 3rd February 2021, signed on the Board's behalf by: Nicolas Breteau, Group Chief Executive Officer, TP ICAP plc and Robin Stewart, Chief Financial Officer, TP ICAP plc.

          Nicolas Breteau
          Chief Executive Officer, TP ICAP

          Robin Stewart
          Chief Financial Officer, TP ICAP

        • Women in Finance Charter
          At TP ICAP we aim to create an environment that is inclusive, diverse and harnesses talent from all backgrounds. ‘Include’ is the third pillar of our ‘A Voice for All’ corporate social responsibility strategy and is about building the diverse and skilled workforce we need for the future.
          We are committed to improving levels of gender diversity, ethnic and socio-economic diversity across the business and ensuring all our employees have a voice. This was why we signed the Women in Finance Charter.
          The Women in Finance Charter reflects the government’s aspiration to see gender balance at all levels across financial services organisations. We agree a balanced workforce is good for business – it is good for our clients, our shareholders and – most importantly – our employees.
          When we signed up to the Charter in September 2018, we had 16% senior female representation within the business and our headline target was to achieve 25% senior women in the business by the year 2025 (and a midway target of 20% senior women by the end of 2022). As of September 2020, we can report we have 31.03% female representation in senior management. We have therefore exceeded our Charter target five years ahead of our deadline and we will continue to improve upon this figure through a series of measures including:

          recruitment - by ensuring our recruitment providers offer short-lists for advertised roles including at least one woman; and by providing unconscious bias training for senior managers;

          development - to help women reach their full potential at every level across our business through mentoring initiatives and through support from our connect D&I advisory board and our women’s networks globally and,

          culture - through our ongoing championing of an inclusive environment through a number of enhanced family friendly policies and guidelines on flexible working and by doing more to increase the visibility and acceptability of options for all employees with caring responsibilities.

          The reasons for this acceleration in reaching our targets is as a result of us continuing to grow and develop our organisation and our recognition of the need for a revised governance and management structure that betters reflects our company and its organisation. Recent senior hires have also led to larger numbers of senior women as well.

          Our corporate governance practices are well aligned with shareholder interests. In addition to our statutory obligations, we have chosen to disclose the following information as part of our ESG Reporting Framework.

          Governance Disclosure

          Overview of Core Metric(s)

          2021 Disclosure

          Political Contributions

          Standard(s)

          GRI section 415.1

           

          Executive Owner(s)

          Robin Stewart, Group CFO

          Disclosure of total amount of political contributions made.

          £nil

          It is the Company’s policy not to make cash contributions to any political party. However, within the normal activities of the Group, there may be occasions when an activity might fall within the broader definition of ‘political expenditure’. Therefore, the Company has sought to obtain shareholder authority to make limited political donations at each AGM. During 2021, no political donations were made by the Group.

          ESG fines

          Standard(s)

          GRI section 307-1

           

          Executive Owner(s)

          Robin Stewart, Group CFO

          Provision for fines and settlements specified for ESG issues in audited accounts.

          £nil

          Incorporation of ESG factors into

          brokerage activities

           

          Standard(s)

          SASB FN-IB-410a.3

           

          Executive Owner(s)

          Regional Heads of Global Broking:

          Don McClumpha, EMEA; Shawn

          Bernardo, Americas; Tom Lovell,

          APAC;

          Energy & Commodities: Andrew

          Polydor, CEO

          Description of approach

          to incorporation of ESG

          factors in brokerage

          activities

          Incorporation of ESG Factors in brokerage activities is detailed in our

          Sustainable Finance section

          Business Ethics – Professional Integrity

          Standard(s)

          SASB FN-IB-510a.1

           

          Executive Owner(s)

          Philip Price, Group General Counsel

           

          Total amount of monetary losses as a result of legal proceedings with fraud, insider trading, anti-trust, anti-competitive behavior, market manipulation, malpractice, or other financial industry laws or regulations

          TP ICAP recognises its responsibility to fully meet its legal and regulatory requirements to protect the integrity and stability of the financial markets and through its activities makes a commitment to:

          • not be used by criminals to launder the proceeds of crime, or by sanctioned individuals and entities;
          • help combat terrorist financing;
          • comply with economic and trade sanctions issued by relevant governments and organisations in every jurisdiction in which we operate;
          • ensure that neither the firm, nor any other person providing services ‘for and on behalf of’ it, facilitates tax evasion;
          • prohibit the acceptance, or offering of a bribe in any form;
          • prohibit the solicitation of business by the offering of any form of bribe;
          • prohibit the offering of employment, with the intention of receiving an improper business advantage; and
          • prohibit the making of facilitation payments.

          TP ICAP strives to maintain the highest standards of honesty, openness and accountability, and recognises that all those who work with or within the Group have an important role to play in achieving this goal. Accordingly, the Group has a global whistleblowing policy which encourages employees and third parties to report suspicion of

          wrongdoing in relation to TP ICAP activities including: criminal activity, failure to comply with legal or regulatory requirements, miscarriages of justice, danger to health and safety, damage to the environment, bribery, financial fraud, negligence, breach of TP ICAP’s policies, and unauthorised disclosure of confidential information.

          EMEA

          AMER

          APAC

          £36,000; €5,005,400

          $206,500 .

          $50,000 .

          Systemic risk management

          Standard(s)

          SASB FN-IB-550a.2

          Executive Owner(s)

          David Goodchild, Group Chief Risk

          Officer

          Description of approach

          to incorporation of

          results of mandatory

          and voluntary stress

          tests into capital

          adequacy planning,

          long-term corporate

          strategy, and other

          business activities.

          TP ICAP conducts robust assessments of the principal risks facing the

          Group, including those that would threaten its business model, future

          performance, solvency or liquidity, and reputation. As part of our risk

          management process, the Group undertakes stress testing and

          scenario analyses to enhance its understanding of its risk profile. This

          includes the conducting of reverse stress tests to identify those risks

          which could render the Group’s business model unviable in an

          extreme scenario.

          Effective risk management is essential to the financial strength and resilience of the Group, and for delivering its business strategy. The Group manages its risk profile through its enterprise risk management framework (‘ERMF’). The Group recognises that to ensure the effective operation of the ERMF, it must implement an appropriate risk management culture that fosters the desired risk management values and behaviours, and that is aligned to TP ICAP’s values. This includes promoting an environment of openness that

          encourages the reporting and discussion of risk-related matters and

          incidents.

          The Group seeks to achieve the implementation of its risk management culture through a range of actions. These include the setting of an appropriate ‘tone-from-the-top’, clear communication of risk management expectations and responsibilities, and through remuneration structures that effectively support the achievement of the desired risk management behaviours.

          A robust risk framework will also enable us to play our role in maintaining the integrity and professionalism of the markets where

          we operate and should also be a competitive differentiator for our

          clients who are increasingly looking beyond liquidity and pricing to

          broader ESG considerations when selecting their service providers.

          Promoting Transparent and Efficient Capital Markets

          Standard(s)

          SASB FN-EX-410a.1

          Executive Owner(s)

          Philip Price, Group General Counsel

          Number and average duration of a) halts to public release of information and b) pauses related to volatility

          The Group has numerous trade and transaction reporting requirements that it has to meet, which are both regulatory and exchange driven.

          The majority of the Group’s reporting requirements are completed by integrated, end-to-end reporting systems across a wide range of regulatory regimes, for example MiFID II and TRACE. With these in place, the Group has effective systems and controls to alert us of any breaches to the timings of the publication of this data, which would allow us to remediate issues as soon as possible.

          The Group recognises that accurate and timely reporting is essential to transparent and efficient markets; to achieve this, the Group has an ongoing programme of work to improve the stability of its reporting systems and infrastructure.

          Number and average duration of

          a) halts to public release of information: nil

          b) pauses related to volatility: nil

          Managing conflicts of interest

           

          Standard(s)

          SASB FN-EX-410a.1

          SASB FN-EX-510a.2

           

          Executive Owner(s)

          Philip Price, Group General Counsel

          Amir Zaidi, Group Head of Compliance

          Total amount of

          monetary losses as a

          result of legal

          proceedings with fraud,

          insider trading,

          anti-trust, anticompetitive

          behaviour,

          market manipulation,

          malpractice, or other

          financial industry laws

          or regulations

          Confidence in TP ICAP’s integrity to act on behalf of its customers is central to the relationship of trust we have with our customers. This means that when providing services, TP ICAP will always act in the customer’s best interests, putting customers’ interests ahead of itsown.

          The Group has put in place the necessary policies and procedures to

          meet its obligations with regards to the identification, prevention and management of conflicts of interest.

          TP ICAP has robust internal policies and procedures in place which require all staff to identify and escalate any identified conflicts of interest, whether business or personal, in accordance with a formal escalation process. Such internal obligations enable the Group to continually identify new conflicts of interest which arise in its business and to implement those measures required to adequately monitor, manage and control the potential impact of those conflicts on its customers.

          Managing Business Continuity and Technology Risks

          Standard(s)

          SASB FN-EX-550a.1

          Executive Owner(s)

          Martin Ryan, Group Chief Operating

          Officer

          Number of significant market disruptions and duration of downtime

          Throughout 2021, TP ICAP experienced no IT or Business Continuity incidents that caused significant market disruption or had a material adverse effect on our business.

          Managing Business Continuity and Technology Risks

          Standard(s)

          SASB FN-EX-550a.2

          Executive Owner(s)

          Martin Ryan, Group Chief Operating

          Officer

          Number of data breaches, percentage involving personally identifiable information, and number of customers affected

          No data breaches were experienced during 2021 within the TP ICAP perimeter.

          Managing business continuity and

          technology risks

          Executive Owner(s)

          Martin Ryan, Group Chief Operating

          Officer

           

          TP ICAP’s Business Continuity Management (‘BCM’) practices are governed globally, with the objectives of ensuring the safety of staff, minimising the impact of a business disruption, providing effective crisis management, and allowing for the continuation and recovery of critical systems and services. BCM is embedded in TP ICAP’s culture, and the Group is committed to maintaining processes and

          plans to enable critical functions to continue following a disruptive event. A formal governance structure exists with documented responsibilities, including regional management and executive oversight via Risk Committees.

          TP ICAP’s Crisis Management teams are organised on a global and regional level: Gold (Global, Strategic), Silver (Regional, Tactical), and Bronze (Office, Operational). Crisis Management is the initial response to a major disruption, designed to resolve any incident quickly without the need to relocate or reduce critical TP ICAP business operations. TP ICAP has regional Silver Teams with detailed plans to provide an effective and timely response to disruptive events of varying severity and type. TP ICAP has also invested in an Emergency Notification System to facilitate timely, effective global alerts to TP ICAP employees during a disruptive event.

          All events must be escalated in accordance with the Group’s Event Rating and Escalation Scale, as stated in the Group’s Enterprise Risk Management Framework. TP ICAP operates a comprehensive Change Management process for all technology changes, including regional and global Change Advisory Boards, which meet weekly and where all changes are reviewed for approval. Any failed changes are tracked with associated problem tickets as part of a failed change problem management process. IT incidents are tracked and managed based upon severity of incident against an application and IT Services tiering scale. A formal problem management process is operated to track actions arising from incidents, with thematic reviews for repeat incidents or common patterns.

            Environmental Disclosure

            Core Metric(s)

            Standard(s)

            Executive Owner(s)

            Carbon emissions

            Three years of total operational Green House Gas (GHG) emissions data (Scope 1 and 2)

            CDP

            GRI section 305-1 and 305-2

            Martin Ryan, Group Chief Operating Officer

            Energy Use

            Three years of total energy consumption data

            CDP

            GRI section 302-1

            Martin Ryan, Group Chief Operating Officer

            Social Disclosure

            Core Metric(s)

            Standard(s)

            Executive Owner(s)

            Employee Diversity Inclusion

            Percentage of gender and racial/ethnic group representation for (1) executive management, (2) non-executive management, (3) professionals, and (4) all other employees

            SASB FN-IB-330a.1

            Sue Maple, HR

            Staff Turnover Rates

            Full-time staff voluntary turnover rate calculated against the average number of full-time employees during the year to create a consistently comparable figure year-on-year.

            GRI section 401-1

            Sue Maple, HR

            Share of Temporary Staff

            The percentage of the workforce that is employed temporarily or on a contract basis.

            GRI section 102-8

            Sue Maple, HR

            Employee Training Hours

            Hours spent on employee development training to enhance knowledge or individual skills (not including training time on Company policies, e.g., safety, code of conduct)

            GRI section 404-1

            Sue Maple, HR

            Charitable Donations

            Total amount of corporate or Group donations and community investments made to registered not-for-profit organisations.

            GRI section 201-1

            Richard Newman, Marketing & Comms

            Governance Disclosure

            Core Metric(s)

            Standard(s)

            Executive Owner(s)

            Political Contributions

            Disclosure of total amount of political contributions made.

            GRI section 415.1

            Robin Stewart, Group CFO

            ESG fines

            Provision for fines and settlements specified for ESG issues in audited accounts.

            GRI section 307-1

            Robin Stewart, Group CFO

            Incorporation of ESG Factors in Brokerage Activities

            Description of approach to incorporation of ESG factors in brokerage activities

            SASB FN-IB-410a.3

            Heads of Global Broking: Don McClumpha, EMEA; Shawn Bernardo, Americas; Tom Lovell, APAC;

            Energy & Commodities: Andrew Polydor, CEO

            Business Ethics – Professional Integrity

            • Total amount of monetary losses as a result of legal proceedings with fraud, insider trading, anti-trust, anti-competitive behavior, market manipulation, malpractice, or other financial industry laws or regulations

            • Description of whistle-blower policies and procedures

            SASB FN-IB-510a.1

            FN-IB-510a.2.

            Philip Price, Group General Counsel

            Amir Zaidi, Group Head of Compliance

            Systemic Risk Management

            Description of approach to incorporation of results of mandatory and voluntary stress tests into capital adequacy planning, long-term corporate strategy, and other business activities.

            SASB FN-IB-550a.2

            David Goodchild, Group Chief Risk Officer

            Promoting Transparent and Efficient Capital Markets

            • Number and average duration of a) halts to public release of information and b) pauses related to volatility

            • Description of alert policy regarding timing and nature of public release of information

            SASB FN-EX-410a.1

            SASB FN-EX-410a.3

            Philip Price, Group General Counsel

            Amir Zaidi, Group Head of Compliance

            Managing Conflicts of Interest

            • Total amount of monetary losses as a result of legal proceedings with fraud, insider trading, anti-trust, anti-competitive behavior, market manipulation, malpractice, or other financial industry laws or regulations

            • Description of processes for identifying and assessing conflicts of interest

            SASB FN-EX-510a.1

            SASB FN-EX-510a.2

            Philip Price, Group General Counsel

            Amir Zaidi, Group Head of Compliance

            Managing Business Continuity and Technology Risks

            • Number of significant market disruptions and duration of downtime

            • Number of data breaches, percentage involving personally identifiable information, and number of customers affected

            • Description of efforts to prevent technology errors, security breaches and market disruptions.

            SASB FN-EX-550a.1

            SASB FN-EX-550a.2

            SASB FN-EX-550a.3

            Martin Ryan, Group Chief Operating Officer