This statement is published on behalf of Exiger Limited (Company 8613726) pursuant to section 54 of the UK Modern Slavery Act 2015. Exiger Limited is a wholly-owned subsidiary of Exiger Holdings, Inc., a company headquartered in New York.
In conducting our business, Exiger is committed to protecting and maintaining all internationally recognised human rights with respect to our employees, the communities in which we operate, and the communities within which our supply chains operate globally. This statement reflects our approach to both modern slavery and human rights, and details the action Exiger Limited took during the 2018 financial year to address the risk and steps in prevention of modern slavery in our operations and supply chain, and how we intend to improve these efforts moving forward.
Who We Are and What We Do
Exiger is a global regulatory and financial crime compliance and risk management company. Exiger arms financial institutions, multinational corporations, and governmental agencies with the practical advice and technology solutions needed to prevent compliance breaches, respond to risk, remediate major issues, and monitor ongoing business activities. Exiger works with clients worldwide to assist them in managing their critical challenges effectively while developing and implementing the policies, procedures, and programs needed to create a sustainable compliance environment.
By the end of the 2018 financial year, Exiger employed approximately 479 people, with offices in the United States, United Kingdom, Canada, Hong Kong, and Singapore. Alongside our staff, independent contractors and data service suppliers play a key role in our client-facing teams and in providing our diligence and technology service.
Our Approach to Human Rights and Modern Slavery
Exiger is led by Executive Chairman Mike Cherkasky and CEO and President Michael Beber, who leads the Board of Directors of Exiger Limited, our UK-based affiliate. Exiger’s Board of Directors provides both leadership and a strong tone from the top regarding ethical conduct.
Exiger was founded to conduct the largest ever court-appointed monitorship of a global financial institution. We are committed to conducting business in a responsible manner. Integrity—one of our company’s seven guiding principles—is embedded in Exiger’s culture through our Code of Conduct, which outlines the values and high ethical standards of both personal and corporate conduct expected of everyone who works for, or with, Exiger.
Exiger is committed to ensuring that no modern slavery or human trafficking takes place within our business. We have a zero-tolerance policy towards forced or bonded labour; we ensure all our terms of employment are voluntary and adhere to local laws with respect to minimum age requirements, wages, overtime, and working hours; and we expect the same from our suppliers, contractors, and third parties. Further, Exiger employees are encouraged to ‘speak up’ and raise any concerns of potential or actual ethical conduct breaches.
Our Assessment of the Risk to our Organisation and Supply Chains and Supplier Due Diligence
Exiger has assessed that our organisation’s modern slavery risk is relatively low. Exiger is a consultancy in the governance, risk, and compliance space. Exiger employs a highly skilled workforce and, according to the Global Slavery Index, operates almost exclusively in countries with a lower prevalence risk of modern slavery.
Moreover, Exiger subjects all permanent staff and independent contractors to a criminal background check prior to onboarding. Additionally, Exiger subjects its data service suppliers to enhanced due diligence through Exiger’s bespoke third party management software, DDIQ and Insight 3PM. This technology uses artificial intelligence to conduct public records research and negative news screening, and also risk rates our suppliers to enable Exiger to closely monitor higher-risk suppliers. Our highest risk data service suppliers are subject to daily negative news screening to ensure we can quickly identify and monitor any new risk.
Exiger’s operational procurement consists primarily of office facility services, such as security and cleaning, and product purchases, such as laptops, office supplies, and marketing materials. To prevent subcontracting and the risk of modern slavery further down these supply chains, Exiger ensures responsible procurement practices, such as avoiding unreasonable expectations and excessive downward pressure on pricing.
Exiger Limited’s London office obtains facilities services from one supplier. This supplier is a signatory to the UN Global Compact, publicly declaring their commitment to business integrity. The supplier has published their own Modern Slavery Statement explaining the steps they have taken to prevent modern slavery and human trafficking from their supply chains. We will continue to review this relationship to ensure such standards are maintained.
Our Plans for the Future
Although Exiger has never identified a human rights breach within our organisation or our supply chains, we are not complacent. We are committed to continually improving our efforts to identify, address, and prevent modern slavery. We commit to:
Updating our Code of Conduct to document our specific commitment to address any ethical issues (including modern slavery);
Developing a more robust due diligence process for our operational procurement, including modern slavery training for procurement staff to increase their awareness of the risks within our supply chains and to encourage greater consideration of a supplier’s ethical performance as a deciding factor in procurement selection; and
Mapping the supply chain of Exiger branded merchandise through the first and second tier, to identify product source, and identify and address potential modern slavery risk further down the chain.
Exiger Limited’s Board of Directors reviewed and approved this statement and, as a declaration of its commitment to address and prevent modern slavery within our business and our supply chains,
Ron Collins signed this statement on the behalf of the Board of Directors on July 1, 2019.
Director and CFO