MODERN SLAVERY STATEMENT

Introduction

This statement sets out Positive Lending’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.

As part of the Financial Services Industry, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking and we continue to take our responsibility very seriously during the coronavirus pandemic.

Our organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of Positive Lending:

• Positive Lending’s key supply chains are provided by professional service firms based entirely in the UK. No sub-contracting is permitted.
• Banking and lending services are provided by UK registered institutions, which may use call centres operating outside the UK.
• Positive Lending’s operates and is regulated within the UK.

The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

• New lenders being added to our panel undergo a review of key policies and this is subject to sign off by the relevant manager, the compliance director and CEO
• New introducers are vetted through the relevant regulator.

Positive Lending has not, to its knowledge, conducted business with another organisation which has been found to have been involved with modern slavery practices. If such an instance is found to have occurred the relationship will be terminated immediately.

Responsibility for our anti-slavery initiatives is as follows:

Policies:

The Compliance Director in conjunction with the HR Director and CEO review legislation and regulation changes and review our internal processes, procedures and policies as required:

• Risk assessments: Vetting of new lenders and introducers
• Investigations/due diligence: vetting is carried out by allocated staff and supervised by relevant team management
• Training: Staff undergo regular industry focused training across all aspects affecting their role.

Relevant policies

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Whistleblowing policy: We encourage all our workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers, or others who have concerns can contact our Head of Compliance and Business Assurance initially in confidence – [email protected].
• Employee code of conduct: Our codes of conduct and business culture make it clear to employees the actions and behaviour expected of them when representing Positive Lending.
• Supplier code of conduct: We are committed to ensuring that our suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of our supplier code of conduct will lead to the termination of the business relationship.
• Recruitment policy: Where we use recruitment agencies we use only specified, reputable employment agencies to source staff and always verify the practices of any new agency to be used before accepting workers from that agency.
• Other policies relevant to our business or sector: We have other relevant policies to ensure consumers are treated fairly and that staff can identify any element of vulnerability. We have corporate social and environmental responsibility policies in place.

Due diligence

We undertakes due diligence when considering taking on new suppliers, introducers, and business relationships, and regularly reviews its existing suppliers. Our due diligence and reviews include:

• mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking
• evaluating the modern slavery and human trafficking risks of each new supplier
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping