This statement has been published in accordance with the requirements of the Modern Slavery Act 2015.
Advantage Finance Ltd (AFL) supports the objectives of the Modern Slavery Act (the 'Act') in raising awareness of modern slavery and human trafficking. As required, this statement sets out the steps taken by AFL to prevent the possibility of modern slavery and human trafficking occurring within its direct operations or supply chains. All information and data provided below is based on a review of business operations reflective of the financial period February 2022 - January 2023.
Within the 2022 publication of this statement, AFL stated intentions to carry out further work in the following areas:
- Submit the updated Modern Slavery Statement to the government's Modern Slavery Statement Registry on an annual basis.
- Review the key business relationships across the company and assessment of whether the scope of our reviews in relation to modern slavery requires extending.
- Implement anonymous whistleblowing procedures.
Development has taken place during 2022 in order to facilitate implementation of these objectives.
2. Organisation Structure and Supply Chains
Advantage Finance Ltd (AFL) provide motor finance facilities for customers throughout the UK and are authorised by the Financial Conduct Authority (FCA), who are the financial regulator for consumer credit in the UK.
AFL are a subsidiary of S&U Plc, a FTSE listed firm established in 1938. All group operations are conducted wholly within the UK. AFL predominantly operates from a Head Office site in Grimsby, N E Lincolnshire. AFL currently have a staff force of apx 200 employees who are, in the main, based at the Grimsby site, with a small number of employees undertaking field-based operations. The headquarters of S&U Plc are based in Solihull, West Midlands.
Neither AFL, nor any other entities of the group operate in any areas generally considered to have a high risk of incidence of modern slavery and human trafficking.
For the purposes of the Act, AFL considers itself to be involved with two primary supply chains:
1. The supply chain involved in the acquisition of customers who purchase motor finance related products (e.g. motor dealers)
2. The supply chains involved in the provision of professional and office services (e.g. office supplies).
AFL does not consider either of the above to be high risk sectors for modern slavery and human trafficking. The group is opposed to slavery and human trafficking in both its direct operations and in the indirect operations of its supply chains. As such, AFL will not knowingly support or conduct business with any organisation involved in slavery or human trafficking. This commitment is underpinned by both the firm's policies on Modern Slavery itself, and supporting policies in relation to:
- Equality of Opportunity
- Recruitment and Selection
- Board Recruitment and Induction
- Anti-Bribery and Corruption
- Health and Safety
- Conduct Risk
- Introducer Compliance
- Financial Crime
AFL do not generally use third parties for the procurement of employment services, and all direct employees are thoroughly vetted prior to their respective employment. Having therefore assessed our employment arrangements and HR Policies, AFL have determined that any risk of a modern slavery related offence being committed is low.
3. Policies in Relation to Slavery and Human Trafficking
AFL are committed to ensuring appropriate cultural awareness exists within the firm's workforce, that is representative of the firms desired attitudes in relation to both;
- The prevention of Modern Slavery and Human Trafficking, and
- The associated measures taken to ensure compliance with the Act.
The firm has developed an internal 'Modern Slavery Policy' which, alongside this statement, will be reviewed at annual intervals, signed off by the Board of Directors, and re-issued to all staff on a yearly 'read and confirm' basis. The policy is fully accessible at all times, to all employees, via access to the firm's internal policy management system. The provision of this policy seeks to ensure that the firm and its employees comply with relevant legislation, and helps to promote good working practices.
4. Due Diligence ProcessesOur Supply Chains
1. The procurement of motor finance related products.
Customers are introduced to AFL by UK only, licenced Credit Brokers (motor finance brokers and motor dealers). AFL will only engage with firms that are approved and regulated by the FCA. AFL believe that this chain of supply is not considered to be a high-risk sector in respect of modern slavery and human trafficking.
AFL are committed to ensuring that modern slavery and human trafficking offences do not occur in our supply chains or in any part of our business, and that where applicable, introducers can demonstrate awareness, accountability and adherence to the Act. AFL will only commence a relationship with an introducer where a 'Business Relationship Agreement' exists between both parties, and where a formal due diligence process has taken place. This agreement will include (by virtue of entering in to said agreement) signed confirmation from the introducer of their own awareness to act in accordance with the requirements of the Act.
2. The provision of professional and office services.
As part of day to day 'business-as-usual' operations, AFL will engage with and acquire products/services from a range of suppliers in the fields of office supply and professional business services.
We believe that this chain of supply is not considered to be a high-risk sector in respect of modern slavery and human trafficking, however, we do recognise that elements of some areas of supply may originate from locations in Asia, Europe and North America. During 2019, AFL introduced an annual 'Modern Slavery Supplier Review' (see sections 5 and 7 below) to improve its assessment of risk within its supply chain. This review is undertaken on an annual basis, with results reported to the firms Board of Directors.Internal Operations
In order to minimise the risk of modern slavery or human trafficking occurring within the firm, AFL have ensured that a range of HR processes and procedures are in place
Prior to employment, the HR team will collect evidence to demonstrate that the person being hired:
- Is who they claim to be
- Has the right to legally work in the UK (such as the provision of a valid passport)
- Has the right to undertake work in accordance with the position offered
- Has a valid UK driving license (where use of a company vehicle is required)
- Has a valid UK bank or building society account
Furthermore, all prospective employees are required to declare any criminal convictions.
Evidence is collated using information provided by the applicant and, where applicable, the DVLA.
All AFL employees are paid by BACS into a UK bank or building society account, at a rate not less than the requirements of the national minimum wage.
AFL is committed to the highest standards of equality, honesty, openness and accountability in line with our company policies and practices (including, and not limited to, all aforementioned policies within this statement itself). All employees are encouraged to raise concerns relating to potential breaches of policy or regulation. Employees can raise a grievance in line with the firms 'Grievance Procedure' should they so wish, and furthermore have full access to the firms 'Whistleblowing Policy'.
5. Risk Assessment and ManagementAssessment
Although AFL perceives the threat of Modern Slavery as low risk within our current market sector, the business accepts that risks are still apparent, no matter how small. To this end, Modern Slavery has been added to the firms Risk Register during 2021 as an area of monitored risk and has been assigned to a formal Risk Owner within the business. The Risk Owner will review associated risks and the requirements of the Act on a periodic basis. This review will extend to the need for the provision/production of the firm's annual statement, its content, and any supporting business practices. Where changes are required in order to conform to the continued requirements of the Act, changes will be made to respective policies and training materials and sent for board approval prior to internal publication to all employees.
The firm's current assessment of risk in relation to Modern Slavery is representative of the following findings;General Operations
At the current time, it is our opinion that neither AFL nor any entities of the group, operate in any areas generally considered to have a high risk of incidence of modern slavery and human trafficking; however in order to facilitate appropriate awareness and culture around the subject matter, all employees are subject to periodic training (see section 6 below). The results of this training are recorded and maintained by the firm's Risk Assurance Department.Supply Chain - Motor Dealers
As per section 2 of this statement, customers are introduced to AFL by licenced Credit Brokers (motor finance brokers and motor dealers) within the UK only. AFL will only engage with firms that are approved and regulated by the FCA. AFL believe therefore, that this chain of supply is not considered to be a high-risk sector in respect of modern slavery and human trafficking - however, in order to underpin confidence with compliance in this area of the supply chain, all firms must enter in to the aforementioned 'Business Relationship Agreement' with AFL prior to introducing business (see section 4.1). The 'Anti-Bribery and Modern Slavery' element of this agreement draws the introducers attention and agreement to the following points, in that they should;
- Be compliant with all applicable laws
- Not to engage in activity that would constitute in a legal offence
- Maintain their own policies and procedures to ensure compliance with associated Acts
- That the procurement of employees, officers, agents and subcontractors within their own supply chains will take place in line with the requirements of the Act
Section 2 of this statement atones that AFL believe this element of the supply chain is not considered to be associated with a high-risk sector in respect of modern slavery and human trafficking. AFL do, however, recognise that elements of some areas associated with the absolute origin of manufacture may originate from locations in Asia, Europe and North America (potential suppliers of a supplier to AFL). In these instances, AFL are only party to the final UK based supplier/distribution elements of these supply chains.
Following commitments outlined in the firms 'Plans for the Future' set out in AFL's 2019 Modern Slavery Statement publication, AFL have introduced a process within our aforementioned annual Modern Slavery Suppliers Review that enables the business to demonstrate that our 'core' suppliers have procedures in place to combat modern slavery - thus placing emphasis on suppliers to demonstrate their own compliance with the Act in ensuring appropriate practice is been adhered to further down the chain.Recruitment
Section 2 of this statement atones that AFL do not generally use third parties for the procurement of employment services, and that all direct employees are thoroughly vetted prior to their respective employment. Having therefore assessed our employment arrangements and HR Policies, we have determined that any risk of modern slavery related offences being committed is low.
Respective HR Policies are maintained and reviewed on an annual basis by the firms Human Resource Manager.Financial Crime
The motivation for the perpetrators of modern slavery and trafficking is often financial profit. Under the Slavery and Trafficking Reparation Orders detailed within the Act, the importance of a swift and thorough financial investigation into those convicted of modern slavery offences is emphasised, with potential consequences including the seizure of funds and assets.
AFL acknowledges the importance of vigilance in the area of financial crime, and the potential impact of modern slavery practices in this area, and as such have developed a robust Financial Crime policy with clear guidelines for all staff on how this impacts on operational duties. High deposit limits are set in line with industry guidance, with any deposits exceeding limits referred to the Money Laundering Officer (MLRO) or Nominated Officer (NO) for review. The MLRO or NO will consider all cases and pass on information to the National Crime Agency (NCA) on cases if deemed necessary. Quality reviews in this area are carried out on a monthly basis by the Risk Assurance Department. All staff at AFL have a responsibility to be alert to Financial Crime and report any suspicions appropriately in line with the policies and procedures set out in the Financial Crime policy. All staff are required to undertake training and a test on this policy upon commencement of their employment, and re-test annually, or sooner should updated guidance be issued.
In June 2019, AFL developed a 'Modern Slavery Awareness' document. This was produced in conjunction with information and statistics obtained from the Home Office via a selection of materials available at the government's modern slavery webpage.
This document is reviewed and updated (where necessary) on an annual basis alongside our Modern Slavery Policy, and then distributed to all employees in the business with the most recent version of the firms Modern Slavery Statement.
Employees are required to confirm they have received and read all distributed documents; following this process, all employees are required to undertake a 'Risk Management Test'. Questions in relation to Modern Slavery practice/policy are contained within the testing document, and employees must attain a pre-determined/high percentage pass mark in order to demonstrate knowledge, competency and understanding of the subject matter.
Training is undertaken by all new employees at the commencement of their employment. Re-testing is scheduled at annual intervals for all staff at all levels of the business, irrespective of the position held, further demonstrating the firm's commitment to the development and maintenance of appropriate culture.
7. Key Risk Indicators (KRI's)
As outlined in Section 5 of this statement, Modern Slavery has been added to the firms Risk Register as an area of monitored risk, and has been assigned to a formal Risk Owner within the business. In order to evaluate performance/risk, and to ensure continued compliance, the Risk Owner has 3 'Key Risk Indicators' (KRI's) at their disposal;KRI 1 - Review of Policy Management
AFL are committed to reviewing and (where necessary) updating all company policies and associated training material on an annual basis - or sooner should changes in regulation dictate. Monthly checks are made to ensure that all Policy Owners are carrying out the review process in line with the firm's 'Policy Implementation Policy'. A record of pending policy updates is communicated both individually to Policy Owners in advance, and collectively to the board of Directors in the firm's monthly Risk Assurance report. Where a significant change/update is made to a company policy, it will be further reviewed and approved by the firm's board of Directors, prior to the information being published to all employees within the firm.KRI 2 - Training Evaluation
As documented in sections 5 and 6 of this statement, AFL have committed to undertaking a period of training and testing for all employees in order to raise awareness of the subject matter and evidence culture. Testing is undertaken by all new employees joining the business in conjunction with the reading of supporting company policies and training documentation. Following annual review of these documents by a Policy Owner (and subsequent approval changes by the board of Directors), this process is then repeated annually to ensure all staff are kept up to date with the latest requirements and changes to legislation.
All employees in the business have successfully completed this training in 2022. A record of individual results is maintained by the firms Risk Assurance Department.KRI 3 - Results of Annual Modern Slavery Suppliers Review
As documented in section 5 of this statement, AFL have implemented a proportionate process that will enable us to demonstrate that core suppliers operating within our professional and office services supply chain have appropriate procedures in place to combat modern slavery. The process is known as our Modern Slavery Suppliers review.
This review seeks additional assurances from key suppliers (those meeting minimum net spend thresholds) to demonstrate their own compliance with the 'Act. Evidence is obtained by way of provision of each firm's own Modern Slavery statement/policy.
8. Summary of activities for the year ended January 2023Modern Slavery Suppliers Review
As documented in sections 5 and 7 of this statement, the Modern Slavery Suppliers review seeks additional assurances from key suppliers (those meeting minimum net spend thresholds) of their own compliance with the Act; evidence is obtained by way of provision of each firm's own Modern Slavery statement/policy.
The 2022 review concluded that;'The review demonstrates that all firms denoted as representing an elevated proportion of risk to the business have demonstrated an awareness of their obligation to comply with the legislation under the terms of the Modern Slavery Act 2015.'
As such, a low risk rating was afforded to this review area.
The framework and parameters used to determine 'key' suppliers has been reviewed as part of the overall risk review, as well as consideration given to the key business relationships covered by the scope of the review; the current parameters have been deemed proportionate and suitable for the sector in which we operate. It is AFL's intention to continue to undertake this review on an annual basis, taking in to account any internal policy changes resulting from any legislative updates to the 'Act'.Whistleblowing Policy
A review of the Whistleblowing policy and procedures has taken place during the review period, this enables employees to report any and all concerns in confidence and without prejudice; changes were made during 2022 to provide the facility for manual reports to be made anonymously. No concerns were raised either internally or from external sources concerning modern slavery in our direct business operations or our supply chain during the review period.Staff Training
As detailed in section 6 of this statement, specific training on the Modern Slavery Act is undertaken by all new employees upon commencement of their employment, with the requirement for annual re-testing for all members of staff. A review of the company Modern Slavery policy and associated training material has taken place during 2022, with the updated policy and Modern Slavery Awareness document re-distributed to all staff along with the updated Modern Slavery Statement. All employees in the business have successfully completed this training in 2021. A record of individual results is maintained by the Risk Assurance department.Risk Review
Modern Slavery is listed as a standalone risk on the business' risk register, and was reviewed by the formal risk owner during 2022, with the conclusion that 'the business is still complying with existing laws and recommendations regarding modern slavery'.Collaboration with relevant agencies
AFL remain committed to working with appropriate law enforcement and fraud prevention agencies in order to provide assistance, where required, in combating modern slavery. To this end, AFL continue to subscribe to the National Vehicle Crime Intelligence Service (NaVCIS), and remain active members of CIFAS, the UK's Fraud Prevention service.Government Modern Slavery Statement Registry
In March 2021 the government launched the Modern Slavery Statement registry, designed to bring statements together in one place, making it easier to search for statements and scrutinise the action organisations are taking to identify and address modern slavery risks in their operations and supply chains. AFL signed up to this registry during 2021 and submitted the business' most recently published statement here as well as on the company website; AFL will commit to continuing to submit future statements to the Modern Slavery registry.
9. Our Plans for the Future
In order to meet the requirements of the Act, it is our intention that we will;
- Review associated business risks on the firm risk register periodically
- Review our Modern Slavery Policy on an annual basis (or sooner should regulation dictate)
- Review our Modern Slavery Statement on an annual basis and seek Board approval for all Statements prior to publication
- Publish updates to our Modern Slavery Statement on our website
- Submit the updated Modern Slavery Statement to the government's Modern Slavery Statement Registry on an annual basis
- Review the key business relationships across the company and assessment of whether the scope of our reviews in relation to modern slavery requires extending
- Continue to promote positive relationships with appropriate law enforcement and fraud prevention agencies as a means of actively creating barriers to those who aim to profit from modern slavery and trafficking.
- Consider the viability of implementing an automated anonymous whistleblowing procedure
In order that our employees can continue to demonstrate their understanding of company policy (and through it the requirements of the business to conform to the requirements of the Act), it is our intention that we will;
- Review our Modern Slavery Awareness training module on an annual basis in line with our company policy (or sooner should regulation dictate)
- Ensure all new employees are subject to training requirements at the inception of their employment contract
- Ensure all existing employees are subject to annual retesting
In order that we can continue to evidence the compliance of supply chains in accordance with the Act, it is our intention that we will;
- Commit to repeating our Modern Slavery Supplier Review on an annual basis, taking in to account any reviewed changes to associated benchmarks as denoted in the firms Modern Slavery Policy
- Obtain evidence from qualifying Professional Office Suppliers in order to demonstrate their awareness and application of the requirements of the Act
- Ensure that all Motor Suppliers (Introducers) enter in to a signed business relationship agreement, that seeks agreement to the points outlined in section 5 of this statement.
10. Board Approval
This statement has been prepared for (and approved by) the Board of Directors of Advantage Finance Ltd.
This statement was approved for publication on 9th March 2023, and will be subject to annual review in January 2024.
11. Sign Off
This statement is hereby signed by:
Date: 9th March 2023