Modern Slavery Act Statement
Introduction and Purpose
The Modern Slavery Act 2015 (the “Act”) is a UK law which came into force in 2015. The Act requires commercial organisations with an annual turnover of more than £36 million, to publish a slavery and human trafficking statement for each financial year. This is Newable’s first Modern Slavery Act Statement and Newable is fully supportive of the Act. As required by the Act, now that Newable is likely to exceed the minimum turnover threshold for the first time, this statement sets out the steps taken during the financial year ended 31 March 2019 to combat slavery and human trafficking in our business and supply chains, and the further steps that we will continue to take.
Newable has a zero tolerance approach to any form of modern slavery. Newable 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 or human trafficking, taking place within our business or partnership or supply chain.
Our commitment to our clients is very clear, we will always treat people in our businesses, partnerships or supply chain fairly. Newable expects its employees, suppliers and business partners to act responsibly and to comply with the requirements of this statement.
Our Business Activities
Newable’s purpose is to make a sustainable profit from helping other businesses thrive, principally by providing services to UK Small and Medium Sized Enterprises (“SMEs”).
As a group, Newable’s strategy is to provide money, advice and workspace for clients. Newable also aims to make finance fairer, easier and more accessible to businesses. The legal entities that undertake lending and mortgage broking activity are authorised and regulated by the Financial Conduct Authority (FCA). The alternative funds business is an Appointed Representative of a Fund Manager that is also authorised and regulated by the FCA.
As a group Newable has in excess of 350 staff in our nationwide offices and all of our business is within the UK, which Newable believes is a lower risk jurisdiction.
Our Partnership and Due Diligence Practices
Newable’s partners or suppliers are predominantly based in the UK. Our partners or supply chain includes business partners in the provision of mortgage services, alternative funds, office space, brokers and distributors; and also providers of other services necessary to run our business effectively, such as IT, payroll and facilities.
Our employees who arrange significant contracts with partners or suppliers will be requested to undertake a risk assessment prior to the commissioning of any new partner or supplier, which will consider slavery and human trafficking risks prior to entering into significant new partner or supplier contracts. We have a separate Partnership Transparency Statement which our current and future significant partners or suppliers will be asked to sign to confirm that they are aware of the Act and will comply with the Act, in order to reduce or remove the risk of slavery or human trafficking in their own businesses. Risk assessments and potential additional due diligence will be undertaken by Newable for those partners or suppliers deemed higher risk or who are located in higher risk jurisdictions.
All procurement is based on objective and fair criteria that reflect the principles of non-discrimination, equal treatment, transparency, procedural fairness, mutual recognition, proportionality and business efficiency. In addition to carrying out due diligence on prospective partners or suppliers, as part of any tender process (where applicable) prospective partners or suppliers are expected to confirm their agreement to Newable’s contractual terms and conditions, and confirm that they will comply with Newable’s policies and procedures and provide the services in accordance with all applicable laws and regulations. Newable expects its partners or suppliers to exercise due diligence along its partnership or supply chain. Newable has the right to end its relationship with a business partner if the supplier or business partner does not comply with these requirements or take alternative action if the supplier or business partner is not able to prove to Newable’s satisfaction, that it has implemented immediate countermeasures to prevent comparable violations occurring in future. Newable is introducing additional specific obligations in its agreements with partners or suppliers requiring partners or suppliers to comply with all laws relating to slavery and human trafficking and to undertake that there is no trafficked, bonded, child or forced labour within their supply chain. Newable has the ability to terminate the relevant contract immediately if the partner or supplier does not comply with these requirements.
Partners or suppliers will be requested to notify Newable prior to sub-contracting any significant services, and that they will ensure that any sub-contractors also comply with the Act. Newable will request the right to audit partners or suppliers where deemed necessary, and to potentially terminate contracts based on any unfavourable results.
Newable treats its employees with respect and dignity and operates internal policies to ensure that it is conducting its business in an ethical, considerate and transparent manner. Newable’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 of each of its suppliers and business partners. 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 compensation and benefits 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.
Newable has a whistleblowing policy intended to encourage and enable employees to report suspected wrongdoing and raise serious concerns within the workplace. Newable is committed to ensuring that any employee concerns are taken seriously and investigated.
Further Steps and Employee Training
Following the publication of Newable’s first Modern Slavery Act Statement, Newable will develop a broader understanding of the areas within our businesses that require further focus to identify potential risks which relate to modern slavery and human trafficking. To ensure that there is a high level of staff awareness of issues relating to modern slavery and human trafficking, Newable will require relevant employees to complete modern slavery and human trafficking computer based training. The training will raise awareness and understanding of the changing expectations around human rights and modern slavery risks.
This statement has been approved by the Board of Directors of Newable on 17 July 2019 who will review and update it as necessary on an annual basis. This statement will be published on Newable’s website.
Chris Manson – Chief Executive Officer
Michael Walsh – Chief Financial Officer
08 January 2020