My Account

Modern Slavery

1. Overview

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 2023 - January 2024.

Following on from the publication of our 2023 statement - and in addition to the annual review processes set out within section 9 of this document - AFL have carried out additional work in the following area:

  • Facilitation of a wider review of key 3rd party professional and office suppliers that extend beyond our current policy thresholds in order to provide an enhanced level of assurance.

The net outcome of this work has resulted in the following enhancements:

  • The addition of the following supply chains within our annual 'Professional Suppliers Review'
    • Legal Services
    • Banking Institutions
    • Recovery Agents
    • Auction Houses
  • Retrospective updates to the firms 'Modern Slavery Policy'
  • Retrospective updates to the firms 'Risk Register'

Our review of these additional cohorts found that there was evidence/confirmation from each of the representative firms of their acknowledgment of the act by way of their own annual statement, company policy, or testimony.

Additionally, where AFL have entered into a professional association with a firm to engage on behalf of the firm, the case for compliance has been further substantiated via the provision of signed business relationship agreements between AFL and the firm in question which include terms that state acknowledgement of, and agreement to, comply with the legal requirements of the Act.

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
  • Whistleblowing
  • Anti-Bribery and Corruption
  • Hospitality and Gifts
  • Conduct Risk
  • 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. Although the firm - on occasion - use recruitment agencies to source high potential candidates, all interviews, right to work checks, credit checks and employment references are completed by the HR department prior to an employment offer being made.

Having assessed our employment arrangements and HR Policies, AFL have determined that any risk of a modern slavery related offence being committed internally by the firm 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 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 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.

As per Section 1 of this document, our review of this areas has now been more widely expanded.

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. In 2023, AFL became a Real Living Wage employer, and are therefore committed to paying employees at a rate that is commensurate with at least the minimum requirements of the scheme.

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 Management

Assessment

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 Enterprise Risk 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
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.

AFL have committed to 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 being 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 Director.

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 firm’s 1st line Quality Control 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.

6. Training

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 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’. An advanced report of pending policy updates is communicated both individually to Policy Owners and Directors in advance of each documents expiry period. 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 2023. A record of individual results is maintained by the firms Enterprise Risk 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 within our policy) to demonstrate their own compliance with the Act. Evidence is obtained by way of provision of each firm’s own Modern Slavery statement/policy, and/or signed Business Relationship Agreement.

8. Summary of activities for the year ended January 2024

Modern 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 as per our company policy) of their own compliance with the Act; evidence is obtained by way of provision of each firm’s own Modern Slavery statement/policy and/or Business Relationship Agreement.

The 2023 review concluded as follows;

'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.'

The subject of Modern Slavery remains on the firms Risk Register, with controls oversight designated to the firms Chief Risk Officer and Enterprise Risk Director.

All controls are monitored and reviewed on a period basis, with updates and evidence recorded within the firms Enterprise Risk framework.

As such, a low risk rating was afforded to this review area.

As per Section 1 of this document, the framework and parameters used to determine ‘key’ suppliers has been reviewed as part of our overall risk review, with 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. The firm facilities a procedure aligned with our policy that enables employees to report any and all concerns anonymously, in confidence, and without prejudice. There have been no concerns raised during the 2023 business year in relation to Modern Slavery.

Staff Training

As detailed in section 6 of this statement, specific awareness 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 2023, 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 2023. A record of individual results is maintained by the firms Enterprise Risk Department.

Risk Review

Modern Slavery is listed as a standalone risk on the firms’ risk register and was reviewed by the formal risk owner during 2023. The risk review comprises of the following controls:

  • Review of Government/Home Office Updates
  • Review of Business Introducers
  • Review of Professional Officer Suppliers
  • Review of HR Policies and Recruitment Practice
  • Review of Financial Crime Policy
  • Review of Staff Training
  • Confirmation of Formal Submission of Home Office Statement
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 our company website. AFL will commit to continuing to submit future statements to the Modern Slavery registry where requirements to do so dictate.

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
  • 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.

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 agreed by the executive Board of Directors on the 24th of January 2024, to be published on the 6th February 2024 subject to confirmation of financial year end turnover.

This statement will be subject to annual review in January 2025.

11. Sign Off

This statement is hereby signed by:

The AFL Board of Directors

Publication Date: 6th February 2024