Exiger Limited’s Human Rights and Modern Slavery Statement

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 2019 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 equips 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 2019 financial year, Exiger employed approximately 546 people, with offices in the United States, United Kingdom, Canada, Hong Kong, Romania, 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 services.

Our Approach to Human Rights and Modern Slavery

Exiger is led by Executive Chairman Mike Cherkasky and by CEO and President Michael Beber, who also 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.

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.

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 to 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 our organisation’s modern slavery risk to be 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 of product purchases, such as laptops, office supplies, and marketing materials. To minimize 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, a public declaration of 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 Progress During the Previous Financial Year

Although Exiger has never identified a human rights breach within our organisation or our supply chains, we are not complacent. During the previous financial year we have:

  • Updated our Code of Conduct to include specific commitments we have made for addressing ethical issues, including modern slavery;
  • Updated our procurement process to ensure a more robust due diligence process during new supplier onboarding. In the event that we are considering entering into a high-risk relationship with any supplier, such relationship with will be vetted by our internal Client Selection and Conflict Management Committee. If accepted, the relationship will be subject to ongoing monitoring to ensure compliance with our high ethical standards; and 
  • Implemented an anonymous ethics and compliance reporting hotline, available 24 hours a day to all Exiger employees, in all our host country languages, to ensure that any individual wishing to submit an incident report may do so without fear of retribution.

Our Plans for the Future

We are committed to continually improving our efforts to identify, address, and prevent modern slavery. Moving forward, we commit to:

    • Providing modern slavery guidance to our operational procurement staff to further increase awareness of the risks within our supply chains. We will encourage greater consideration of ethical performance as a deciding factor in procurement selection; and

    • Mapping the supply chain of Exiger branded merchandise; this includes reviewing our vendors, identifying product sources, and identifying and addressing potential modern slavery risks 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 June 30, 2020

Director and CFO