Anti-Slavery Policy

Last updated September 2018

INTRODUCTION

This statement is made pursuant to section 54, Part 6 of the Modern Slavery Act 2015 (the Act) and sets out the steps that Loans 2 Go has taken and our commitment to improving our practices to ensure that slavery and human trafficking is not taking place in our supply chains or any parts of our business.

Loans 2 Go has a zero-tolerance approach to any form of modern slavery. Loans 2 Go is committed to acting in an ethical manner, with integrity and transparency in all business dealings and is committed to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within its business or supply chain.

BUSINESS

Loans 2 Go limited entered the consumer credit market in the UK in 2002 with the objective of providing an affordable, simple and straightforward alternative to people who may have less than perfect credit profiles by providing personal loans secured on vehicles by way of Bill of Sale and unsecured personal loans. Currently, we offer loans of between £400 and £50,000, with fixed repayments over 12 to 36 months with no arrangement or set-up fees. Loans 2 Go is a member of the Consumer Credit Trade Association and is authorised and regulated by the Financial Conduct Authority (FRN 679836).

We recognise that modern slavery exists in many forms across many industry sectors and we are committed to act ethically and with integrity in all our business relationships and are opposed to slavery and human trafficking in our direct operations and in the indirect operations of our supply chain. As such, we will not knowingly support or do business with any organisation or individual involved in slavery or human trafficking.

As a financial services provider, we have relatively straightforward supply chains compared with those of other sectors, with the majority of procurement being sourced from suppliers based in the UK. However, we consider that in certain geographical locations within the UK, the cheque cashing and pawnbroking services offered to our customers may increase our exposure to transacting with those involved in slavery and/or human trafficking.

POLICIES

The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

  • Whistleblowing policy – Loans 2 Go has a whistleblowing policy intended to encourage and enable staff to report suspected wrongdoing and raise serious concerns within the workplace. Loans 2 Go employees, business associates and other third parties are provided with internal and external contact points to report on legal and regulatory violations, including suspicions of human rights violations, in connection with us. Loans 2 Go is committed to ensuring that any staff concerns are taken seriously and investigated.
  • The Employee Handbook – The code of conduct communicated in the Employee Handbook sets down the actions and behaviour expected of employees when representing the Company.

EMPLOYEES

Loans 2 Go treats it employees with respect and dignity and operates internal policies to ensure that it is conducting its business in an ethical and transparent manner. Loans 2 Go’s policies and procedures are reviewed and updated on an annual basis and are available to staff on a shared drive.

Loans 2 Go’s recruitment policies ensure that employee screening checks are carried out to ensure that the individual is legally entitled to work in the UK to safeguard against human trafficking or individuals being forced to work against their will and expects the same from its business associates. Employees are free to leave their employment after reasonable notice and are not required to lodge deposits of money or identity papers with their employer. The remuneration paid to employees for a normal working week comply at least with guaranteed minimum legal requirements, including minimum wage legislation and working hours comply at least with the national legal standards and are not excessive.

DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

As Loans 2 Go is not in an industry with a high risk of modern slavery, a risk-based approach has been adopted to review its supply chains. As part of our initiative to identify and mitigate risk we carry out appropriate due diligence when seeking to enter into business relationships with our business associates through our compliance due diligence process. The Company’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of business partners. This due diligence document has been updated to include information relating to a prospective supplier’s compliance with the Modern Slavery Act. In addition, Loans 2Go has the right to audit suppliers for compliance with applicable laws, including the supplier’s obligations to comply with all laws relating to slavery and human trafficking.

TRAINING

To ensure a high level of understanding of the risk of modern slavery and human tracking and our policy, Loans 2 Go will provide training on the requirements of the Act and our policy to all relevant staff.