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Modern Slavery

Modern Slavery Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. At PCF we have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

PCF’s Modern Slavery Policy was approved by the Board in June 2020.

 

Our Business

PCF Bank provides different business activities across the United Kingdom and in the case of its subsidiary, Azule this is extended to Europe. The two largest and most established business units of the Bank are a consumer motor finance division (CFD) and a business finance division (BFD), which provide hire purchase and finance lease facilities to consumers and corporate customers respectively. Both divisions operate a finance broker introduced model within the United Kingdom.

The Savings and Customer Service business unit provide the opportunity for UK customers to save with the Bank. The Bank’s Bridging department provides short-term loans to individuals against property and is used by the borrower as a temporary financing solution before transitioning to another financial arrangement or selling the property.

Azule operates a broking and lending business specialising in the financing of leases and hire purchase agreements for broadcast and media equipment. Azule has a small Irish subsidiary and operates across Europe.

 

Our Supply Chain

We have a ‘Supplier Assurance Framework’ in place which details the supplier risk management systems we use as part of the due diligence processes and when onboarding new suppliers. As part of our due diligence process, suppliers are asked about the measures they take to ensure modern slavery and human trafficking is mitigated in their supply chains, whether they have guidelines on modern slavery in their own terms and conditions with suppliers, whether they conduct regular risk assessments and how they train their employees to identify and report on modern slavery. Every new supplier is presented with our ‘Supplier Code of Conduct’ which details the company’s position on modern slavery.

 

Responsibility

The Board has overall responsibility for ensuring that our policy and statement complies with our legal and ethical obligations, and that all those under our control comply with it. The Head of Risk & Compliance/Head of HR has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and reviewing internal control systems and procedures to ensure they are effective in countering modern slavery.

 

Compliance

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. These individuals are required to avoid any activity that might lead to, or suggest, a breach of this policy. Any suspicions of a conflict with this policy must be reported to the Head of Risk and Compliance/Head of HR and everyone is encouraged to raise any concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

 

Awareness

Training on Modern Slavery, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary. Our suppliers are provided with the ‘Supplier Code of Conduct’ (which is part of the company’s Supplier & Outsourcing Assurance Framework) as part of the onboarding process.

 

Breaches

We may terminate our relationship with other individuals and organisations working for us, or on our behalf if they breach the principles of our Modern Slavery policy and statement.

 

On behalf of the Board

Scott Maybury

Chief Executive

21 July 2020