Modern Slavery Statement
This statement has been published in accordance with 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 as of March 2019 unless otherwise stated.
Modern Slavery Policy and Culture
AFL are committed to ensuring appropriate cultural awareness exists among our workforce 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. To this end, 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. Furthermore, the policy is fully accessible to all employees via access to the firm's internal policy management platform. 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.
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 is a subsidiary S&U Plc, a FTSE listed firm established in 1938. The group operations are conducted wholly within the UK. AFL currently operate with a staff force of 160 employees, operating predominantly from its base in Grimsby, N E Lincolnshire, with a small number of employees undertaking field based operations. The headquarters of S&U Plc is based in Solihull, West Midlands.
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. For the purposes of the Act, AFL considers itself to be involved with two primary supply chains:
- The supply chain involved in the acquisition of customers who purchase motor finance related products (e.g. motor dealers)
- 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 polices in relation to:
- Equality of Opportunity
- Recruitment and Selection
- Board Recruitment and Induction
- Anti-Bribery and Corruption
- Health and Safety
- Conduct Risk
- Introducer Compliance
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, we have determined that any risk of modern slavery related offences being committed is low.
Our Supply Chains
1. The procurement of motor finance related products.
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. We 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 a formal due diligence process has taken place, which will include confirmation (and periodic re-certification) of their own awareness and application of the requirements of the Act, where applicable.
2.The provision of professional and office services.
As part of its 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 intends to undertake work to improve its assessment of risk within its supply chain (see 'Our Plans for the Future' below).
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 are required to collect evidence that shows 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
All prospective employees are also required to declare any criminal convictions.
This evidence is obtained using information provided by the applicant and, where applicable, by the DVLA.
All 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 all aforementioned polices within this statement itself). All employees are encouraged to raise concerns relating to potential breaches of regulations, policy requirements and/or other grievances, including the ability to act in accordance with the firms Whistleblowing Policy.
Our Plans for the Future
Following the publication of AFL's first statement on Modern Slavery and the implementation of a formal company policy, we will be reviewing how we can best drive awareness of the subject matter within the business in 2019.
In order that our employees can further demonstrate their understanding of company policy (and through it the requirements of the business to adhere to the Act), we aim to implement a testing module within our current regulatory knowledge testing framework. The results of this testing will further demonstrate the depth of understanding amongst our employees in relation to Modern Slavery, and help to evidence appropriate culture within the firm.
During 2019 AFL will be introducing a framework that demonstrates core suppliers operating within our professional and office services supply chain have appropriate procedures in place to combat modern slavery. This exercise will take a proportionate approach in respect of:
- Those suppliers perceived to be operating in an area of heightened risk
- Those suppliers that meet the minimum turnover requirements in line with the Act
- Those suppliers that meet the internal threshold of a pre-determined sum
This statement has been approved by the Board of Directors of Advantage Finance Ltd, and will be subject to annual review in March 2020.