CNPJ 37484255000187



Anti-slavery and
Human Trafficking Statement

This statement is made in accordance with section 54(1) of the UK Modern Slavery Act 2015
and sets out the steps Trading BitBaxter and its subsidiary businesses, namely
Trading BitBaxter, aim to help tackle modern slavery and human trafficking. This statement
constitutes our Modern Slavery and Human Trafficking Statement for the financial year
commencing 09/09/2023 and ending 09/09/2024.

“We, at Trading BitBaxter, seek to promote respect for human rights and the prevention of acts of
modern slavery and human trafficking from occurring within our business and supply
chains alike. We recognise this as a serious global issue and are dedicated to the ongoing
improvement of our systems and playing our part in combating modern slavery and
human trafficking diligently and with integrity. We strive to establish commercial relations
with suppliers that do not tolerate such abhorrent practices and abide by the same high
standards as we do ourselves.

As a financial institution, we are aware of our role and responsibilities in combating this
unlawful practice. We are setting in place a designated internal policy, and we are
developing a strategy and processes so as to engage in thorough due diligence and risk
monitoring in respect of our business line and suppliers. No occurrences of modern slavery,
human trafficking, or any such exploitation have been recorded.
We are presently raising more and more awareness among our employees via interactive
training courses dedicated to identifying and effectively preventing instances of modern
slavery and human trafficking. This statement further looks into our future steps to tackle
this grave violation of fundamental human rights.”

1. Our business structure, mission and supply

Trading BitBaxter, and its Group companies, , is a
fintech company providing online financial services to retail clients. BitBaxter operates in
core geographic markets like the Brasil and the EU through its principal, fully authorised trading
entities. BitBaxter employs around 320 people and has a global annual.
Our mission is democratising the financial markets with free, smart and easy-to-use mobile
app and investment brokerage platform enabling anyone to trade Stock, ETFs, Forex,
Commodities and more. As of 2023, BitBaxter’s client base has grown to more than 1.5
million retail clients.
Given its regulatory statuses with Gov.Brasil, Trading BitBaxter is required to and
continues to operate at the highest standards to meet its regulatory obligations and
supervisory expectations in respect of servicing retail clients. To that end, we adhere to the
same standards when it comes to combating pressing issues like modern slavery both
within and outside our organisational structure. You can find out more about the nature of
our business, mission and values here.

In order to provide our services to clients, we work with a range of suppliers in key sectors
facilitating our business. Our supply chains comprise a network of suppliers, contractors and
other stakeholders in IT (software, hosting, and maintenance for our internal systems),
marketing, consultancy, facilities management, recruitment, etc.
We thoroughly check supply chains to ensure the potential for slavery and human trafficking
is significantly reduced. We are presently engaged in reviewing our procurement and supply
chain processes so as to ensure greater transparency. This will help us more easily identify if
there are any modern slavery and human trafficking concerns within our supply chains and
act accordingly by taking the relevant action.

2. Policies, Procedures and Standards

Modern slavery is a complex and multifaceted crime, and tackling it requires all of us to play
a part. As part of our commitment to combating modern slavery, we are developing a
designated Anti-slavery and Human Trafficking Policy, which applies to every Trading BitBaxter
colleague. Our Policy features:
● what modern slavery is;
● what our responsibilities are;
● the principal areas of risk we may face;
● our mechanisms and processes in place to check our supply chains;
● our recruitment process;
● how to identify and report slavery; and
● our training practices.
We are further aware of modern slavery considerations as part of our anti-money
laundering activities and acknowledge them in our Anti-money Laundering Policy.
Where possible, we also endeavour to ensure that our suppliers are aware of our policies.

3. Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking
occurring within our supply chains, we are adopting due diligence procedures.
Our procedures are being designed to:
● establish and assess areas of potential risk in our business and supply chains;
● monitor potential risk areas in our business and supply chains;
● reduce the risk of slavery and human trafficking occurring in our business and supply
● provide adequate protection for whistleblowers.

4. Risk Assessment and Compliance

We seek to ensure that there is no modern slavery or human trafficking in our supply chains
or in any part of our business. Upon evaluating the nature and extent of BitBaxter’s
exposure to the risk of modern slavery occurring in our supply chain, and as a duly
authorised financial services company, BitBaxter is at low risk of modern slavery and/or
human trafficking occurring within the business.
Furthermore, we do not tolerate slavery and human trafficking within our supply chains. We
will not engage with a supplier, contractor or any other third party if we suspect that they
might be involved in any unlawful practices specifically related to modern slavery and
human trafficking.

5. Effectiveness of Measures and KPIs

As a result of the development and implementation of our internal strategies, guidelines,
and procedures, no occurrences of modern slavery, human trafficking, or any such
exploitation have been recorded either within, or outside our organisational structures.
Trading BitBaxter shall adopt key performance indicators (KPIs) to measure how successful we
have been in ensuring that slavery and human trafficking is not taking place in any part of
our business or supply chains. These are as follows:
● Completion of a firm-wide interactive training course on modern slavery and human
trafficking; and
● Zero modern slavery reports.

6. Training

Modern slavery training is fundamental to raising awareness within our company and
building our employees’ capabilities to mitigate risks and identify and escalate modern
slavery concerns, if needed, in a proper way. We invest in educating our staff and colleagues
to recognise the risks of modern slavery and human trafficking in our business and supply
chains. Through our training programmes, employees are encouraged to identify and report
any potential breaches of our Anti-slavery and Human Trafficking Policy. Employees are
taught the benefits of stringent measures to tackle slavery and human trafficking, as well as
the consequences of failing to eradicate slavery and human trafficking from our business
and supply chains. An example of training courses we have administered over the past year
include our ‘Modern Slavery’ course available to all our employees at Trading BitBaxter Training

7. Next Steps

Following our review of our actions this financial year to prevent slavery or human trafficking
from occurring in our business or supply chains, we intend to take the following further steps
to tackle slavery and human trafficking:
● Drafting specific contractual terms to include in all our contracts with new suppliers.;
● Reviewing and improving our Procurement Standards;
● Upgrading and diversifying our training courses and materials; and
● Developing and enhancing our modern slavery KPIs.

This statement was approved by the Trading BitBaxter Board of BitBaxter Teamlead on 16 September 2023.

Date: 16.09.2023

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