About this Statement

The statement is made and published in respect of 24Pro ElitehubCorp Financial Services Pty Ltd an Australian registered company (ACN 127 606 348) and Australian Financial Services Licence (AFSL number 318232).

Overview

24Pro Elitehub is a leading global provider of margin foreign exchange and contracts for difference (“CFD”s). We offer fully regulated retail and institutional trading. Founded in Sydney in 2007 and trusted for over ten years, our business has evolved into a world-class, multifaceted brokerage. With heavy investment in the latest trading technology, 24Pro Elitehub seeks to offer the most comprehensive end-to-end trading experience available, servicing traders of all levels from beginners to institutional level clients. The 24Pro Elitehub group operates in Australia under regulations governed by ASIC¹.

24Pro Elitehub supports the Modern Slavery Act 2018 (Australia), whose provisions assist in the eradication of modern slavery, wherever it may occur, and raise public awareness of the issue.

Our Approach

24Pro Elitehub has a responsibility to respect human rights in their operations and supply chains, as outlined in the “United Nations Guiding Principles on Business and Human Rights²”, and this includes appropriate measures to assess and address modern slavery risks. Entities that take action to combat modern slavery in their operations and supply chains can protect against possible business harm and improve the integrity and quality of their supply chains.

At 24Pro Elitehub our vision is to:

make a positive impact on people’s lives everywhere we go

We support and respect the protection of internationally proclaimed human rights and endeavour to make sure that 24Pro Elitehub is not complicit in human rights abuses. 24Pro Elitehub acknowledges the importance of respecting human rights and combating modern slavery that it may be exposed to through its operations or supply chains. We are committed to achieving the highest standards of ethical behaviour in the conduct of our business and activities worldwide.

24Pro Elitehub does not tolerate slavery, human trafficking, abusive or unfair treatment in any part of our business, or in any of our supply chains. Through our policies and procedures for procuring services and resources, 24Pro Elitehub is committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that slavery and human trafficking is not taking place anywhere in our business or in any of our supply chains.

Our operations and supply chain

24Pro Elitehub operates in the financial services sector, which in general, is assessed as low risk in respect to modern slavery. 24Pro Elitehub primarily operates in countries which are assessed by the Global Slavery Index³ as having a lower prevalence of modern slavery with the governments of these countries actively responding to the issues that modern slavery poses.

24Pro Elitehub’s supply chain primarily provides professional and technical services and is considered low risk in respect of modern slavery. 24Pro Elitehub’s suppliers provide services in respect of:

• Liquidity – arranging for clients of 24Pro Elitehub to purchase and sell financial instruments;
• Insurers – providing insurance covering 24Pro Elitehub’s business;
• Payments – banking and processing of payment services;
• Professional Services – provision of audit, legal and professional services;
• Service Providers – providing 24Pro Elitehub with a range of services from leasing of offices, marketing material, through to recruitment services; and
• Technology – information technology hardware and software related services

24Pro Elitehub expects the same high standards from all its contractors, suppliers and other business partners. When considering potential suppliers, 24Pro Elitehub requests suppliers to demonstrate the measures they have in place for combatting modern slavery. 24Pro Elitehub will then make an assessment and determine if the providers policies, procedures, and processes meet 24Pro Elitehub’s requirements and standards.

Policies and Procedures

24Pro Elitehub is committed to acting ethically and with integrity in its business dealings and relationships and to ensure effective measures operate to assist in the eradication modern slavery and reducing the potential risk of this occurring in 24Pro Elitehub’s business and supply chain.

The measures 24Pro Elitehub has in place to mitigate the potential risk of modern slavery include 24Pro Elitehub’s policies and procedures, in particular the:

• Code of Conduct defines what we expect of our people and the way they conduct themselves during their time with 24Pro Elitehub;
• Anti-Bribery and Corruption Policy defining 24Pro Elitehub’s commitment to the deterrence of bribery and corruption;
• Anti-Modern Slavery Policy defines 24Pro Elitehub’s commitment and measures in place to assist in combatting modern slavery;
• Anti-Money Laundering and Counter Financing of Terrorism Policy defining 24Pro Elitehub’s commitment to the deterrence of money-laundering and financing of terrorism;
• Supplier Onboarding and Monitoring Policy and Procedures requires consideration whether it is appropriate to enter into and continue relationships with our suppliers; and
• Whistleblower Policy allowing 24Pro Elitehub staff to raise any concerns they may have about any individuals or organisations which 24Pro Elitehub interacts with.

Supplier Due Diligence

Recognising that the greatest risk of modern slavery is in our supply chain, 24Pro Elitehub will continue to take appropriate measures to ensure that these risks are both managed and reviewed.

• 24Pro Elitehub reviews its assessments of its suppliers and given the nature of 24Pro Elitehub’s business and the suppliers 24Pro Elitehub has relationships with, in respect of modern slavery 24Pro Elitehub is satisfied with these suppliers meet the requirements and expectations
• 24Pro Elitehub’s contractual terms with its suppliers include undertakings that suppliers comply with all applicable laws, regulations, and codes of conduct
• 24Pro Elitehub’s onboarding of new suppliers requires appropriate due diligence is conducted including the potential for modern slavery. Any supplier whose reputation or practices may raise concerns for 24Pro Elitehub, are explored further to ascertain if it is appropriate to onboard such a supplier
• 24Pro Elitehub’s existing relationships with suppliers are reviewed periodically and consider continuance of relationship
• 24Pro Elitehub’s periodic review of its enterprise risk profile includes the assessment of risk relating to modern slavery

Staff Training

24Pro Elitehub’s staff training programme includes training relating to modern slavery which is completed by 24Pro Elitehub staff globally. As part of 24Pro Elitehub’s periodic review of training content, 24Pro Elitehub will consider if further enhancements may be beneficial.

Recruitment and welfare of our people

24Pro Elitehub employs nearly 300 staff members in a number of locations across the globe and values the people that choose to work for 24Pro Elitehub. 24Pro Elitehub uses recruitment firms who meet relevant employment local laws and regulations. 24Pro Elitehub periodically reviews its human resources policies and procedures to ensure these continue to be relevant in respect of respective employment law.

Approval

This statement was prepared by members of 24Pro Elitehub’s risk management division and approved by 24Pro Elitehub’s Risk, Audit and Compliance Committee.

¹ ASIC Home | ASIC - Australian Securities and Investments Commission

² OHCHR | OHCHR and business and human rights

³ The Global Slavery Index provides a country by country ranking of the number of people in modern slavery, as well as an analysis of the actions governments are taking to respond, and the factors that make people vulnerable.