Modern Slavery Statement
1. Our Business
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 2019 - January 2020.
Within the 2019 publication of this statement, AFL stated intensions to carry out further work in the following areas:
Development has taken place during 2020 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 170 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:
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 polices in relation to:
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 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 Processes
Our 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 has undertaken work to improve its assessment of risk within its supply chain by introducing an annual 'Modern Slavery Supplier Review' (see sections 5 and 7 below). This review is undertaken on an annual basis, with results reported to the firms Board of Directors.
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:
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 polices 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 Management
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 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 polices 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;
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;
Supply Chain - Professional Office Supplies
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 new 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.
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.
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 acknowledge 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.
The firm's intention is to review and update this document (where necessary) on an annual basis alongside our Modern Slavery Policy, and then distributed it to all employees in the business with the most recent version of the firms Modern Slavery Statement.
Alongside other risk related policies, upon distribution of the materials, 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 polices 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 firms 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 polices 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 2019. 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.
The 2020 review concluded 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.
It is AFL's intention to repeat this review on an annual basis, taking in to account any internal policy changes resulting from any legislative updates to the 'Act'.
KRI 4 - Cultivation of positive business relationships with appropriate agencies.
AFL are 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 subscribe to the National Vehicle Crime Intelligence Service (NaVCIS), submitting cases of fraud and vehicle theft where deemed appropriate for review by police, and dissemination to police forces as a crime. NaVCIS can combine investigations and share intelligence with UK and EU wide police forces, in order to spot potential large scale or organised gang related criminal activity, which may have links to modern slavery. AFL support this work by providing evidence where able and appropriate, acting on alerts disseminated by NaVCIS, and participating in relevant FLA meetings conducted by NaVCIS to ensure we are vigilant to any emerging threats in this area.
AFL are members of CIFAS, the UK's Fraud Prevention service, receiving access to their database on a reciprocal basis. Victims of modern slavery can often be used by perpetrators for further financial gain by having their identities used fraudulently to claim benefits or other financial products which then directly profit perpetrators. AFL have procedures in place to review in full all CIFAS referrals which suggest that the applicant may have been a victim of fraudulent activity, or subject to a protective registration. AFL work closely with CIFAS as filing categories are constantly reviewed and updated to fully reflect the challenges facing the finance industry when striving to protect victims of financial crime, encompassing the growing area of modern slavery and financial coercion.
8. Our Plans for the Future
In order to meet the requirements of the Act, it is our intention that we will;
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;
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;
9. 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 31st March 2021, and will be subject to annual review in January 2022.
10. Sign Off
This statement is hereby signed by:
Date: 31st March 2021