Legal · last reviewed August 2026

Supplier conduct

A statement of what we require from the firms and individuals we buy from and subcontract to. It is short because the practice’s supply chain is short: software services, professional services, and contract engineers.

What we require

• Lawful and freely given labour. No forced labour, bonded labour or child labour anywhere in the chain, and no retention of identity documents as a condition of work.
• Payment and terms in writing. Contract engineers are engaged on written terms with stated rates and payment periods, and we pay to them.
• No facilitation payments. Of any size, in any jurisdiction, in either direction.
• Confidentiality that survives the engagement. Subcontractors are bound to the same client confidentiality obligations we are, and to the same data handling terms.
• Disclosure of conflicts. Including any relationship with a client or a competitor of a client, before the engagement rather than during it.

What a client can expect of us

We tell you when a subcontractor will work on your engagement, and who they are. We do not subcontract the substance of an advisory recommendation. Where a related party in the group is involved — most often on agent-coordination work involving FlashyOS, built by Flashy Group — that is disclosed at body weight on every page and in the engagement documentation, not in a footnote. The group structure sets out why.

Reporting

Concerns about conduct in our supply chain can be raised at press@mlgblockchain.com. Reports may be made anonymously, and we do not retaliate against anyone who raises one in good faith.

Scope

This statement covers the practice. Group-level policies, including any statutory modern-slavery statement required of the group as a whole, are published by GDA Group where the relevant thresholds apply.