Bullo Platforms LLC FZCO is fully committed to preventing slavery and human trafficking in our corporate activities and ensuring that our supply chains are free from slavery and human trafficking. This commitment is in line with Section 54(1) of the UK Modern Slavery Act 2015, even though our operations are based in the United Arab Emirates, and it reflects our pledge to act ethically and with integrity in all our business relationships.

Organisational Structure and Operations

Bullo Platforms LLC FZCO operates as a provider of simulated trading platforms and educational tools for traders, under the jurisdiction of the International Free Zone Authority (IFZA) in Dubai, United Arab Emirates. Our business is centred around technology solutions and intellectual services, mainly involving software development and customer support within the fintech sector.

Our Commitment

As a responsible corporate entity, Bullo Platforms recognises the importance of the Modern Slavery Act 2015 and its implications for our operations globally. We are committed to continuously improving our practices to combat slavery and human trafficking and ensuring that such practices are not taking place in our business nor any of our supply chains.

Policies on Slavery and Human Trafficking

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we have implemented the following policies:

Modern Slavery Policy: This defines our approach to identifying and preventing slavery and human trafficking in our operations and supply chains.

Whistleblowing Policy: Encourages all our employees, customers, and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation. Anyone can email SpeakUp@Bullo.com to report any Modern Slavery or other concerns, with anonymity.

Supplier Code of Conduct: Communicates our zero-tolerance stance on violation of human rights standards to our suppliers and partners.

Due Diligence Processes

Bullo Platforms conducts due diligence processes to make our supply chain resilient against slavery and human trafficking:

Supplier Audits: We may conduct audits of our suppliers to ensure compliance with our policy on modern slavery. These audits are both in the form of self-reporting questionnaires and proof of Modern Slavery Statements.

Internal Review: Our internal management systems and procedures are designed to ensure that we are not complicit in any human rights violations, including slavery and human trafficking.

Training: We offer training to relevant members of our staff to ensure they understand the risks of modern slavery and human trafficking in our supply chains and our business.

Risk and Compliance

Bullo Platforms recognises that our biggest exposure to Modern Slavery is in our product supply chains, where we undertake ongoing reviews to ensure compliance. Through our engagement with suppliers, we can require them to demonstrate compliance with anti-slavery principles. We have a zero-tolerance policy toward non-compliance with our anti-slavery and human trafficking policy and take appropriate steps, including contract termination, if non-compliance is discovered.

Effectiveness and Key Performance Indicators (KPIs)

We have established the following KPIs to measure the effectiveness of our efforts in combating slavery and human trafficking in our operations and supply chain:

.Number of audits carried out on suppliers regarding modern slavery practices.
.Number of reported modern slavery concerns and the actions taken in response.

Commitment to Ethical Principles

We are committed to ensuring that our suppliers adhere to the highest standards of ethics and human rights. This includes ensuring that all parts of our business and supply chain are free from slavery and human trafficking. We expect the same high standards from all contractors, suppliers, and other business partners.

Reporting on Progress

We will include updates on the actions we're taking to implement our anti-slavery policy within our annual compliance and ethics report, ensuring transparency and accountability in our operational practices.

Conclusion

This Modern Slavery Policy Statement is a clear expression of Bullo Platforms’ commitment to identifying, preventing, and mitigating the risks of modern slavery practices in our business operations and supply chain. We will review and update our policies and practices regularly to stay compliant with legal requirements and best practices in human rights and corporate ethics.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our company's slavery and human trafficking statement for the current financial year.