Modern Slavery Statement for Financial Year 2023

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 (“the Act”) and applies to Wintermute Trading Limited (“Wintermute” or “the Company”) in respect of the financial year ending 31st December 2023.

Our Business

Wintermute is an algorithmic trading firm in digital assets that provides liquidity on trading platforms and via OTC. The office is located in London, UK.

Wintermute is registered as a cryptoasset firm with the Financial Conduct Authority under the Money Laundering Regulations. Wintermute’s business is subject to a wide range of laws and regulations, including Anti-Money Laundering and Counter Terrorist Financing (“AML/CTF”) legislation as well as U.S. Treasury Department’s Office of Foreign Assets Control and applicable sanctions requirements. Wintermute further follows the international framework proposed by the Financial Action Task Force and refers to guidance produced by the Joint Money Laundering Steering Group in the United Kingdom. As part of this registration, Wintermute is committed to developing, implementing and maintaining an effective, risk-based AML/CTF Program, which is reasonably designed to prevent Wintermute from being used to facilitate money laundering, which could be used to finance human trafficking or other modern slavery practices.

Wintermute’s Policy on Slavery and Human Trafficking

Wintermute places great importance on treating its staff and carrying out its business in an ethically principled way. Wintermute has in place a Code of Conduct which sets out the ethical standards of conducts and Wintermute’s general policies to ensure Wintermute staff members and employees conduct themselves in a manner that meets standards of integrity. Wintermute is fully committed to preventing modern slavery practices in relation to the use of our services, through our business operations and across our supply chain.

Wintermute’s Supply Chains

Wintermute operates within the digital asset trading industry. Subsequently, the nature of the entities that makes up the bulk of our supply chain are professional advisors, hardware and software provider and support providers.

Due Diligence Process

Wintermute uses a risk-based approach to assess its supplies. This process includes the use of industry, geographical location, education requirements, and skill level as factors that can indicate where there may be a greater risk of slavery and human trafficking within the supply chain. We continue to carry out the annual supply chain assessment and take further action if deemed appropriate.

Risk Assessment and Management

Wintermute expects that our suppliers will not tolerate any form of exploitation in their business or any party of their supply chain. Based on the assessment that we have carried out, we have determined that the risk of slavery and human trafficking within our supply chain is low.

Despite this, Wintermute is aware that slavery and human trafficking can occur across any sector and supply chain. Wintermute will continue to ensure that its assessments are commensurate with the nature of its business and supply chain, as well as raising awareness internally.