ESG Disclosure Hub

• 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 2022 of £542m (2021: £523m), 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 2022     

• 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 Statement

• 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 service
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. 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). At the end of 2022, we can report we have 25% female representation in senior management. 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.