Policies and documents

The Group Data Protection and Privacy Policy is designed to ensure that the CMC Markets group processes personal data in compliance with all applicable international and local data protection and privacy laws and regulations. CMC processes both employee and client personal data. ‘Personal data’ means any information relating to an identified or identifiable natural person (data subject). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. This policy applies to all personal data processed by CMC and to employees, temporary employees, contractors, service providers, business partners and other third parties who have access to personal data.

CMC will ensure that all personal data it collects is:

• used only for the purposes for which it was collected;
• only collected if required to support business processes;
• an accurate record of the personal data provided;
• maintained and updated;
• disposed of securely when it is no longer needed;
• secured against unauthorised disclosure, amendment or deletion; not transferred to organisations or countries who provide inadequate protection of personal data; and
• processed in accordance with all applicable Data Protection and Privacy laws and regulations, including the person’s data protection and privacy rights.

CMC will also ensure that all persons providing personal data are:

• made aware that their personal data is being collected at the point at which it is obtained;
• informed of the purpose(s) for which their personal data will be used;
• notified where and by whom their personal data may be processed;
• given the option to opt out of use of their personal data for reasons that are not necessary for the provision of services, such as marketing; and
• informed that personal data is processed in accordance with rights to data subjects.

At the point of collection of personal data, and during CMC Markets’ relationship with the data subject, CMC Markets must:

• be clear from the outset about why it is collecting personal data and what it intends to do with it;
• provide individuals with appropriate privacy notices when collecting their personal data.

Personal data must be processed in accordance with all applicable laws. This means that CMC Markets must:

• have legitimate grounds for collecting and using the personal data;
• ensure that it does not do anything unlawful with the data;
• only collect and retain that personal data necessary to provide services and meet legal and regulatory requirements

Last updated: August 2023

All employees must be treated with dignity and respect, free from harassment or other forms of bullying at work and out of the workplace, such as on business trips or at work-related events or social functions.

CMC does not tolerate harassment and bullying in any form. In certain circumstances such actions may also amount to unlawful discrimination, such as discrimination on grounds of gender, sexual orientation, marital or civil partner status, gender reassignment, race, colour, nationality, ethnic or national origin, religion or belief, disability, or age. Employees may also, in some cases, be held legally liable for harassing their colleagues or third parties (including Customers) and may be ordered to pay compensation by a court or employment tribunal.

Last updated: August 2023

CMC Markets Plc and its subsidiaries is committed to promoting equal opportunities in employment. CMC Markets’ employees and job applicants will receive equal treatment regardless of age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation (Protected Characteristics). Our internal policy sets out our approach to equal opportunities and the avoidance of discrimination at work. It applies to all aspects of employment with us, including recruitment, pay and conditions, training, appraisals, promotion, conduct at work, disciplinary and grievance procedures, and termination of employment.

Our Group Equal Opportunities policy is supported by specific elements within several other key policies and procedures as follows:

Group Grievance Procedure - we believe that all employees should be treated fairly and with respect. A grievance is a complaint by an employee about an issue that arises out of the employment relationship. This procedure applies to all employees regardless of length of service. Issues that may cause grievances include:

Terms and conditions of employment; health and safety; work relations; bullying and harassment; new working practices; working environment; organisational change; and discrimination.

We recognise that a formal grievance procedure can be a stressful and upsetting experience for all parties involved. Everyone involved in the process is entitled to be treated calmly and with respect.

Our aim is to deal with grievances sensitively and with due respect for the privacy of any individuals involved. All employees must treat as confidential any information communicated to them in connection with any grievance.

Group Diversity and Inclusion Statement and Policy - in line with CMC’s Diversity and Inclusion Statement CMC Markets plc and all its subsidiaries, associated entities and branch offices, is committed to creating an environment that ensures people are treated fairly and with dignity and respect in all dealings. We firmly believe that fostering a diverse and inclusive organisation creates stronger foundations, a more engaged workforce and in turn enables greater connections with our clients and the wider market in which we operate.

Our Group Diversity & Inclusion policy applies to all persons working for, or on behalf of, CMC Markets plc or any of its subsidiaries (“CMC”) in any capacity, including each director, senior officer, employee (fixed term and permanent), contractor, worker (including agency worker) and intern/trainee. This also applies to employees who work offsite, e.g. where the workplace is not under the control or management of CMC. Our values are applied in the context of all aspects of the employment cycle. It also applies outside of work when socialising with colleagues, attending work related events and when representing the Company externally.

CMC Markets recognises that our people are the most important asset and differentiate us from our competitors. We are therefore committed to promoting a culture that actively values difference and recognises that every employee has the right to be treated with dignity and respect in a culture which is free from discrimination, bullying, harassment and victimisation. We provide equal employment and working opportunities for all employees, and we want to continue to develop this culture to create a working environment that allows us to attract, develop and retain high calibre candidates. Our focus is to ensure that all employees understand the importance of equality and diversity, and to outline the role in which we have in cultivating inclusive and diverse working conditions.

We operate a zero-tolerance policy on discrimination, bullying, victimisation and harassment. We will not tolerate any conduct that is intended to, or has the effect of, discriminating against, victimising or harassing any applicant or employee. This also extends to suppliers, customers or clients of CMC Markets.

The Grievance Procedure is available to all employees who believe they have been unfairly discriminated against. Similarly, the Anti-Harassment and Bullying Procedure is available to employees who believe they may have been harassed or bullied. Our values mean that employees will not be victimised in any way for making such a complaint in good faith. Complaints of this nature will be dealt with seriously, sensitively, and in confidence.

Last updated: August 2023

• You can view our Board Diversity Policy here

Last updated: March 2024

CMC is committed to the highest possible standards of openness, honesty, integrity and accountability. CMC encourages any member of Staff who has a genuine concern about any form of actual or suspected malpractice or unethical behaviour (“Wrongdoing”) occurring within CMC to raise those concerns (“Concern” or “Concerns”) immediately to the Whistleblowing Champion, one of the appointed Whistleblowing Officers or local Compliance Manager. CMC’s Whistleblowing policy and procedures is intended to complement applicable statutory protection and, for the avoidance of doubt, statutory rights of Whistleblower’s will not be affected in any way by this statement.

CMC’s policy and procedures:

• provides a global minimum standard for all persons working for, or on behalf of, CMC in any capacity (“Staff”);
• encourages Staff to report Wrongdoing as soon as possible, in the knowledge that their Concerns will be taken seriously and investigated as appropriate, their confidentiality will be respected and that they will not suffer any detriment or be dismissed as a result of reporting their Concerns;
• provides Staff with guidance as to how to raise those Concerns; and
• reassures Staff that they should be able to raise genuine Concerns without fear of reprisals or victimisation, and to protect Staff from retaliation or being otherwise disadvantaged, even if they turn out to be mistaken (since the victimisation of genuine whistle-blowers including malicious allegations and other abuses of the Policy are disciplinary offences).

Reporting a concern

Concerns can be reported, including anonymously, directly to the Whistleblowing Officers for each office or via Safecall at https://www.safecall.co.uk/en/file-a-report/telephone-numbers/ and https://www.safecall.co.uk/report/.

Last updated: August 2023

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 (UK) and Part 2 of the Modern Slavery Act 2018 (Commonwealth of Australia) and sets out the approach taken by CMC Markets plc (registration number 05145017) and all its subsidiaries and branches, including CMC Markets UK plc (registration number 02448409), CMC Spreadbet plc (registration number 02589529), CMC Markets Investments Limited (registration number 12816952) and CMC Markets Group Australia Pty Ltd (registration number 128 774 890) (the “CMC Group”), to understand all potential modern slavery risks related to our business and the actions undertaken to mitigate any such risks for the financial year ending 31 March 2025.

The CMC Group is not aware of any slavery or human trafficking in any part of its business or supply chain, and we remain dedicated to ensuring that our business and supply chains are free of slavery and human trafficking. The CMC Group is committed to acting with integrity in all its business dealings and relationships and to improving its practices to combat slavery and human trafficking.

Our Business

As one of the leading global providers of online trading and investing, with a comprehensive retail, professional and institutional offering, the CMC Group offers clients the opportunity to trade the financial markets via contracts for difference (CFDs), financial spread betting (UK & Ireland only) and countdowns (professional clients only). The CMC Group also offers a stockbroking service in Australia, Singapore and the UK. As of 31 March 2025, the CMC Group has 1,108 employees worldwide and has offices in various countries.

Our Structure and Subsidiaries

CMC Markets plc is the parent company of the CMC Group. The following entities are direct or indirect subsidiaries of CMC Markets plc and are covered by this statement:

• CMC Spreadbet plc (UK company, registration number 02589529);
• CMC Markets UK plc (UK company, registration number 02448409);
• CMC Markets Investments Limited (UK company, registration number 12816952);
• CMC Markets Investments Nominee Limited (UK company, registration number 13765708);
• CMC Markets CFD Overseas Holdings Limited (UK company, registration number 14940138);
• CMC Markets Holdings Ventures Limited (UK company, registration number 14802277);
• CMC Markets Ventures Limited (UK company, registration number 14839454);
• CMC Markets Holdings Limited (UK company, registration number 09980788);
• CMC Markets Overseas Holdings Limited (UK company, registration number 05554641);
• CMC Markets UK Holdings Limited (UK company, registration number 05554639);
• Information Internet Limited (UK company, registration number 03149891);
• Opto Markets Limited (UK company, registration number 15039587);
• CMC Markets Bermuda Holdings Limited (Bermudan company, registration number 202302717);
• CMC Markets Bermuda Limited (Bermudan company, registration number 202302718);
• Opto Markets LLC (American company, registration number 7653348);
• CMC Markets Germany GmbH (German company, registration number HRB 114199);
• CMC Markets NZ Ltd (New Zealand company, registration number 1705324);
• CMC Markets Canada Inc (Canadian company, registration number 430307-5);
• CMC Markets Singapore Pte. Ltd (Singapore company, registration number 200605050E);
• CMC Markets Singapore Invest Pte Ltd (Singapore company, registration number 202217639M);
• CMC Markets Middle East Ltd (Dubai company, registration number 3039);
• CMC Business Services (Shanghai) Limited (Chinese company, registration number 91310115MA1K3MNN8E);
• CMC Markets Group Australia Pty Ltd (Australian company, registration number 128 774 890);
• CMC Markets Asia Pacific Pty Ltd (Australian company, registration number 100 058 213);
• CMC Markets Stockbroking Ltd (Australian company, registration number 081 002 851);
• CMC Markets Stockbroking Services Pty Ltd (Australian company, registration number 623 114009);
• CMC Markets Stockbroking Nominees Pty Ltd (Australian company, registration number 081 424375); and
• CMC Markets Stockbroking Nominees (No.2 Account) Pty Ltd (Australian company, registration number 081 440 128).

Our Supply Chains, Due Diligence, and Risk Assessment Processes

Given the low-risk nature of financial services, in addition to the global employment practices and skilled workforce it employs, the CMC Group assesses that the risk of modern slavery and human trafficking in its business and supply chain is low. We understand that our largest exposure to possible modern slavery or human trafficking concerns would be in our supply chain, and we continue to uphold a stringent set of internal processes to ensure that we effectively identify, manage and minimise that potential risk exposure.

As part of our initiative to identify and mitigate risk exposure, we carry out due diligence on all new suppliers, agents, consultants and contractors throughout our supply chain. This is to ensure the potential for modern slavery and human trafficking is significantly reduced within our business. Our due diligence process requires multi-level credential checks for all new suppliers in our supply chain. Our dedicated Financial Crime Team conducts ongoing adverse media screening on vendors, inclusive of modern slavery related factors.

Further, during the financial year ending 31 March 2025, our Procurement team has enhanced the supplier onboarding process by implementing a new modern slavery review process (“Enhanced Process”). Under the Enhanced Process, all prospective new suppliers are assessed for more specific modern slavery risks, such as the industry, location and business of the supplier. For those suppliers where the initial review indicates potential modern slavery risks, further due diligence will be undertaken before determining whether to engage that supplier, including by requiring the supplier to complete a questionnaire about whether it engages in any practices that might indicate a modern slavery and/or human trafficking risk. Where relevant risks are identified, our Financial Crime Team will conduct a review in line with their standard procedures, and our Legal Team will assess whether additional contractual protections are necessary for such suppliers.

As reported on in our Modern Slavery Statement for the year ending 31 March 2024, we have a modern slavery notification flag built into our supplier onboarding software, which stakeholders are required to raise if they identify any modern slavery concerns during the due diligence stage. This flag now feeds into the Enhanced Process; as, if a flag is raised, the supplier will be escalated to the appropriate CMC Group stakeholders for a further modern slavery review assessment, which includes reviewing the supplier through the Enhanced Process, if it had not been through such a process already.

The CMC Group expects suppliers and other organisations with which it does business to adopt and enforce policies to comply with applicable modern slavery legislation and does not knowingly support or conduct business with companies that are either involved, or that we reasonably suspect are involved, in modern slavery or human trafficking.

Our Policies on Modern Slavery and Human Trafficking

Our Group Anti-Slavery Policy reflects our zero-tolerance approach to modern slavery and human trafficking. It confirms our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place anywhere in our business or supply chains.

The CMC Group has clear employment processes in place; for instance, our Human Resources Team monitors salary levels across all of our offices to ensure that we exceed minimum pay requirements for all of our employees relevant to the jurisdiction. The CMC Group has a clear set of employment policies in place, which also support our stance on modern slavery. These include, but are not limited to, the Code of Conduct, Group Diversity and Inclusion Statement and Policy, Group Equal Opportunity Policy and Group Remuneration Policy. Failure to comply with these policies can result in disciplinary action against an employee under our Group Disciplinary Policy. CMC Group also has a Group Whistleblowing Policy in place, which encourages employees to report any concerns about any form of actual or suspected wrongdoing, including those related to modern slavery and human trafficking, without fear of reprisal.

The CMC Group Anti-Slavery Policy is reviewed and assessed whenever there is a significant change to relevant regulations, best practice guidelines or business processes. When no such changes occur, the policy is reviewed at least annually to ensure it addresses risks identified during the procurement due diligence process in place.

Consultations with Our Subsidiaries and Associated Entities

All companies within the CMC Group are committed to identifying and mitigating modern slavery and human trafficking risks within the business. Our policies and processes are carried out at a CMC Group level and this statement reflects the CMC Group’s approach to modern slavery. The companies in the CMC Group consult each other and provide intra-group support as and when required.

Key Performance Indicators to Measure Efficacy of Steps Taken ("KPIs")

CMC Group’s processes to address modern slavery and human trafficking risks in our operations and supply chain continue to evolve. Although the risk of modern slavery and human trafficking in our business and supply chain is low, we have continued to work on developing frameworks and processes to assess the effectiveness of the modern slavery and human trafficking measures taken in our operations and supply chains. In the past year, our cross-functional team of relevant business stakeholders, the Modern Slavery Working Group (“MS Working Group”), has continued to meet quarterly to maintain a CMC Effectiveness of Modern Slavery Measures Assessment Framework (“MSAF”). As a key consideration under the MSAF, the MS Working Group has identified existing measures that have been implemented to combat and manage modern slavery risks and attached KPIs to each measure. The MS Working Group meets quarterly to, among other things, measure and track the effectiveness of the processes set out in the MSAF by assessing actions and outcomes for each KPI. Reporting on our procurement due diligence process will also be a further enhancement to our modern slavery processes, so we can assess whether all potential new suppliers are being screened for modern slavery risks, in accordance with the relevant KPI. Any deficiencies identified in these processes will be considered and will inform further discussion on remediation. Aside from considering cross-departmental internal feedback based on an identification of any such deficiencies, consideration of the appropriate course of remediation will also be determined with reference to peer and industry initiatives in relation to assessing and mitigating modern slavery risks.

CMC Group continues to follow the updates and advice provided by notable organisations, such as the Walk-Free Foundation.

Annual Review and Continuous Development

The CMC Group has deployed training courses for its employees worldwide to ensure its staff are fully aware of, and educated about, the impact of modern slavery and human trafficking within our industry and worldwide. This training forms part of the CMC Group’s mandatory annual training programme, which is supported by our Code of Conduct, and which had a 99% completion rate for the 2024/25 staff training programme.

The CMC Group will conduct an annual review of this statement.

Approved by the Board of Directors of CMC Markets plc on 23 July 2025.

Lord Peter Cruddas
Chief Executive Officer
CMC Markets plc

Download Modern Slavery Statement (Signed)

Download Modern Slavery Statement 2024

Download Modern Slavery Statement 2023

Download Modern Slavery Statement 2022

Download Modern Slavery Statement 2021

Download Modern Slavery Statement 2020

Download Modern Slavery Statement 2019

Download Modern Slavery Statement 2018

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Last updated: August 2023

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