Modern Slavery Statement
MODERN SLAVERY STATEMENT
THIS STATEMENT IS MADE ON BEHALF OF SANCUS LENDING GROUP LIMITED PURSUANT TO SECTION 54 OF THE MODERN SLAVERY ACT 2015.
This statement was approved by Rory Mepham, CEO and approved by the Board of Directors at its Board meeting on 16 May 2023. This statement sets out the steps taken to ensure that slavery and human trafficking is not taking place in our business or supply chains.
WHAT IS MODERN SLAVERY?
There is no country in the world unaffected by modern slavery. Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Victims of modern slavery might face violence or threats, be forced into inescapable debt, or have their passport taken away and face being threatened with deportation.
Sancus takes a zero-tolerance approach to any form of modern slavery. This statement looks to recognise the steps put in place by the organisation to ensure there is no human trafficking or slavery in our business and wider supply chain. We are committed to acting ethically, with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
The Company demonstrates respect for human rights and has a zero tolerance of modern slavery throughout the organisation.
The health and safety of colleagues and suppliers throughout the COVID-19 pandemic, and subsequently, has been forefront of mind for the management team at Sancus. We have undertaken regular updates to, and monitoring of, health and safety guidance and policies and review of working from home practices, including through colleague surveys and health and safety assessments. Support for mental health and physical wellbeing has included training for managers to understand how to recognise potential wellbeing issues, and a number of events to raise awareness, including stress awareness month. We are currently in the process of training mental health first aiders to provide further support to colleagues, with four members of staff having successful completed their training and more expected.
Sancus’ Whistleblowing Policy ensures employees can raise any concerns effectively, including those relating to modern slavery and human trafficking. All concerns are investigated, and individuals can escalate to senior management where appropriate. Employees may elect to remain anonymous, and every effort is taken to ensure their identity remains confidential.
We provide all staff with training, relevant to them and their role, including offering specific online training on modern slavery and human trafficking in financial services, which emphasises the role of the financial services industry in combatting this, explains the different types of modern slavery, and gives detail on possible ‘red flag’ indicators. Colleagues are provided with a short guide covering these areas, which is published on our intranet and available to review at any time. We are also committed to delivering effective training to those colleagues who deal with suppliers as part of their role.
As an alternative finance provider, offering bridging and development finance we do not manufacture or produce physical products. Instead, our suppliers are predominantly our office management and associated services cover by their suppliers such as cleaners. Looking downstream, this would include the property development businesses we supply funding to. We ask specific modern slavery/ESG questions during the on-boarding of clients to ensure this key aspect is not over-looked.
Sancus and its subsidiaries are committed to regular reviews, and have a range of policies that include:
- Anti-Bribery and Corruption;
- Anti-Money Laundering;
- Diversity and Inclusion; and
All relevant processes and policies, including in respect of modern slavery and human trafficking, will continue to be reviewed and enhanced during the coming year as part of our continuous improvement initiatives. In particular, our HR policies will be reviewed with a focus on how they relate to modern slavery and human trafficking.
We will continue to work to ensure that policies and procedures are effectively embedded in the Company and any risks are identified, carefully considered and monitored, and appropriately mitigated or managed. We regularly review our approach to tackling modern slavery and human trafficking.
ASSESSMENT OF EFFECTIVENESS
We are committed to increasing the transparency within our supply chain year upon year. We recognise that it is a collaborative approach and that our journey of identifying and minimising the risk of human trafficking and slavery is continuous. We continue to work with our clients to promote best practices and share knowledge on recognising modern slavery within the workplace and supply chain.