Modern slavery statement

Our commitment to preventing slavery and human trafficking in our business and supply chains.

Introduction

This statement sets out Positive Lending's actions to understand all potential modern slavery risks related to its business, and the steps in place to ensure there is no slavery or human trafficking in its own business or its supply chains. As part of the financial services industry, we recognise our responsibility to take a robust approach to slavery and human trafficking, and we are absolutely committed to preventing both in our corporate activities and to ensuring our supply chains are free from them.

Organisational structure and supply chains

Positive Lending's key supply chains are provided by professional service firms based entirely in the UK, and 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 operates and is regulated within the UK.

We assess whether particular activities or countries are high risk in relation to slavery or human trafficking as follows: new lenders being added to our panel undergo a review of key policies, subject to sign-off by the relevant manager, the compliance director and the CEO; and new introducers are vetted through the relevant regulator. Positive Lending has not, to its knowledge, conducted business with any organisation found to have been involved in modern slavery practices; if such an instance were found, the relationship would be terminated immediately.

Responsibility and training

The Compliance Director, in conjunction with the HR Director and CEO, reviews legislation and regulation changes and updates our internal processes, procedures and policies as required. Vetting of new lenders and introducers is carried out by allocated staff and supervised by the relevant team management, and staff undergo regular industry-focused training across all aspects affecting their role.

Relevant policies

Whistleblowing: we encourage all our workers, customers and business partners to report any concerns related to our direct activities or supply chains, including any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our procedure is designed to make disclosures easy and without fear of retaliation; concerns can be raised in confidence with our Head of Compliance and Business Assurance at compliance@positivelending.co.uk.

Employee code of conduct: our codes of conduct and business culture make clear the actions and behaviour expected of employees when representing Positive Lending.

Supplier code of conduct: suppliers are required to demonstrate safe working conditions where relevant, to treat workers with dignity and respect, and to act ethically and within the law in their use of labour. We work with suppliers to meet these standards; serious violations lead to termination of the business relationship.

Recruitment: where recruitment agencies are used, we use only specified, reputable agencies and always verify the practices of any new agency before accepting workers from it.

Due diligence

We undertake due diligence when considering new suppliers, introducers and business relationships, and regularly review existing suppliers. This includes mapping the supply chain to assess particular product or geographical risks of modern slavery and human trafficking, evaluating those risks for each new supplier, and reviewing all aspects of the supply chain on a regular basis.