Legals - Other Policies


SECTION 1 – Modern Slavery Act 2015 Statement

This statement is made on behalf of Icetechtrading Limited. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement.

SECTION 2 – Our Policy

We have a zero tolerance policy when it comes to modern slavery and human trafficking. We are opposed to all forms of modern slavery in whatever form and are committed to contributing to the combatting of it in whichever way we can. We expect all of the suppliers, consumers, counterparties, vendors and partners that we work with and whom we have business relationships with to behave in a way that is consistent with this principle.

Modern slavery is a criminal offence under the Modern Slavery Act 2015 and can take many forms, including child or forced or compulsory labour and human trafficking. Modern slavery occurs when a person is under control of another person, who applies violence and / or force to maintain that control, and the goal of that control is exploitation. We expect all those with whom we have a business relationship to familiarise themselves with our policy and to act at all times in a way that is consistent with this position.

Supply Chain Adherence and Implementation?
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business and in our supply chains.

All of our employees are required to ensure that they are familiar with and comply with our position on modern slavery and human trafficking. Employees should be vigilant and aware in their dealings with suppliers and consumers and if there are any concerns or indications that there is any potential modern slavery, human trafficking or other human rights violations they should notify the compliance team immediately and before proceeding or continuing with any business activity.


The objective of our tax policy is to set forth and formalise procedures to prevent tax evasion from being committed and is based on the following key principles:

1. Risk assessment
2. Implementation of procedures to carry out risk assessment
3. Secure buy in of management to tax policy
4. Due diligence
5. Communication and training
6. Monitoring and review

Summary of Tax Policy
The Company’s approach to overall business is based upon a code of conduct where there is an expectation that its people will carry themselves in such a way that demonstrates personal and professional integrity, ethically responsible behavior and professional excellence. Consistent with this overall philosophy is the expectation of top management that the tax affairs of the Company are managed consistent with this code of conduct. The Company is thus committed to conducting its business in accordance with all relevant laws, rules and regulations and the highest ethical and legal standards. The Company’s approach to tax compliance and planning is to be consistent with these values.

The Company believes it has an obligation to pay the amount of tax legally due in any jurisdiction in accordance with relevant rules and regulations.

Consistent with its code of conduct, the Company will continue its policy of managing its tax affairs responsibly, encompassing a zero tolerance approach to illegal tax evasion and facilitation of such tax evasion.

Scope of Tax Policy
It is intended that this policy apply to all Company entities and operations, whether operated by the Company, an affiliate, or a subsidiary. It shall apply to all employees of the Company, affiliates and subsidiaries. All relevant contractors or third party service providers are expected to agree to the terms of, and abide by, this Policy or to terms substantially the same and no less onerous.

As previously stated the aforementioned objectives will be accomplished by means of a 6 fold procedure:

1. Risk Assessment
To determine the scope and risk profile of each facet of the Company’s business including external and internal relationships and implementation of relevant procedures. Sector, transaction and geographic risks will be identified.

2. Implementation of procedures to carry out risk assessment
Subsequent to such determination the intention is to map existing financial crime controls to inherent risks and identify whether their design and operation is sufficient to mitigate the risks. If required, additional controls and/or procedures will be designed to address the residual risk.

3. Secure buy in of top management to tax policy
Senior management commit to a zero-tolerance approach to the facilitation of tax evasion and other financial crimes.

4. Due diligence
The tax function will be involved in this planning and implementation.

5. Communication and Training
Training on the terms of this Policy will be provided to relevant employees and
the Company will conduct reasonable due diligence and seek to develop reasonable measures to mitigate any such impacts.

6. Monitoring and Review
The Company institutes procedures and controls that specify how financial crime allegations, such as tax evasion and the facilitation of tax evasion, should be reported by employees and stakeholders, and how such allegations are to be investigated.