Modern Slavery Act Statement
This statement is made pursuant to section 54 of the Modern Slavery Act (the “Act”) and constitutes Start-Up Loans Company’s modern slavery and human trafficking statement, as required by the Act for our financial year ended 31 March 2017.
The Start-Up Loans Company (“SULCo”) is a subsidiary of British Business Bank plc (our “parent”). SULCo is committed to the principles of the Act and the abolition of modern slavery and human trafficking. We acknowledge the undertakings in the Act and endeavour to create a culture of transparency with regards to the supply of goods and services to us.
We are committed to ensuring that our supply chain and any part of our business are free from any slavery and/or human trafficking. SULCo and its parent have certain common policies and infrastructure. In the financial year which ended on 31 March 2017, SULCo, together with its parent have taken the following steps in order to combat human trafficking and slavery (‘Modern Slavery’):
- Procured and engaged suppliers and advisers in each case in accordance with a set of policies and procedures which help minimise the risk of Modern Slavery occurring in SULCo, including by only engaging with reputable and credible suppliers.
- Created a system of company policies, by which SULCo employees can identify risks and report wrongdoing. These make it easy for staff to report concerns at an early stage, including concerns relating to Modern Slavery.
- Ensured that any terms and conditions that SULCo signs up to with suppliers (for the provision of services/goods) are subject to the laws of England and Wales and are therefore bound by the Modern Slavery Act 2015.
We, together with our parent, are currently reviewing our supply chain protocols and we intend to undertake the following activities:
(a) Make all staff aware of the Act and inform them of the appropriate action to take if they suspect a case of slavery or human trafficking;
(b) Put together a working group to assess the parts of SULCo’s business and supply chains where there might be a risk of slavery or human trafficking and what steps SULCo should take to manage these risks and to ensure that Modern Slavery is not present anywhere within SULCo’s operations;
(c) Conduct a further review of the policies and procedures of SULCo to consider whether they should be enhanced or supplemented in relation to Modern Slavery;
(d) Conduct a further review of SULCo’s due diligence processes and documentation standards in relation to Modern Slavery to identify any suitable amendments to such processes or documentation standards;
(e) Consider whether it would be appropriate to include a specific requirement in our procurement vetting process for prospective suppliers to disclose their position on human slavery and trafficking and to provide statements as appropriate; and
(f) Consider whether it would be appropriate to include reference to, and compliance with, the Act in our supplier engagement process, supplier audit procedures, and contractual arrangements with third party suppliers.
This statement, which will be reviewed annually and updated as required, has been reviewed and approved by the Board of Directors of The Start-Up Loans Company on 29 September 2017.