Modern Slavery

Our business, Toneality Limited is committed to combating slavery and human trafficking in its business and supply chains, and we make this statement to assist with compliance with the Modern Slavery Act 2015. This statement relates to the financial year ending 2022.

As our business has a turnover of less than £36 million, we do not have a legal obligation to produce a modern slavery statement. However:

  1. We agree that exploitation within all supply chains ending in the UK is a blight on our society, and we are committed to playing our part in eliminating exploitation;

  2. We understand that customers with obligations under the Modern Slavery Act 2015 cannot comply with those duties without our cooperation. 

To that end, we confirm that we have examined our own business and, to the extent that it is reasonably practicable, businesses within our supply chain and we confirm the following:

  1. We confirm that within our own business, no relevant offence relating to slavery or human tracking has been committed. 

  2. We have made enquiries of businesses that supply directly to us and we are confident that no relevant offence is committed in that business. 

  3. Insofar as it was reasonably practicable, we have examined our supply chains and confirm that we found no evidence of slavery or human trafficking. 

Further details about our business and supply chain are provided below. 

Our business provides communication services to the financial markets helping to facilitate voice communications for traders and dealers and providing data banks, brokerages and their customers.

Our business structure is:

  • At the end of 2022 we had employees based in the UK and US.

  • Three directors plus other employees reporting to the directors.

We operate in the following countries:

  • Based in UK and US but operating a global business servicing the financial markets around the world.

Our supply chain is as follows:

Our supply chain consists of the major US Public Cloud providers, financial markets data centres and international Telecommunication providers. 

Toneality Limited has outsourced certain functions to services providers.  Like many of our peers, our supply chain is large and complex with multiple layers.

High level analysis of our supply chain suggests that as most of our suppliers are UK or US based and provide professional services, risk of modern slavery is low.

We ensure that we engage only reputable contractors and suppliers who adhere to the relevant regulations and legislation in the provision of their goods and services.  As part of our commitment to eliminating modern slavery in our supply chains we undertake initial and ongoing checking of suppliers.

We understand that certain industry sectors and geographical regions entail greater risk of exploitation than others. We do not believe that our supply chain is in one of those sectors.   As part of our commitment to eliminating modern slavery in our supply chains we undertake initial and ongoing  checking of suppliers.

Where it is reasonably practicable, we ensure that businesses in our supply chain have made a similar statement relating to slavery and human trafficking.

The person in our function within our business responsible for assessing matters relating to slavery and human trafficking is: legal@toneality.net 

We also encourage all employees to report on any matters relating to slavery or human trafficking in our supply chains of which they become aware.