Modern Slavery Act 2015 Statement


Slavery and Human Trafficking Statement

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 (the "Act") and sets out the steps that the Company has taken to ensure that slavery and human trafficking is not taking place in its supply chains or any parts of its business.
The Company provides loan administration services as to loan assets secured by residential and commercial real estate located in the United Kingdom and is part of the Pepper Group of companies (the "Pepper Group").
The Pepper Group also operates various loan administration businesses, financial advisory and service businesses, and residential mortgage and consumer lending businesses in Australia, New Zealand, Ireland, Spain, South Korea, Hong Kong, Cyprus, Greece and China.
Although we are not required to make a modern slavery statement under section 54 of the Modern Slavery Act 2015, we are making this statement to show our commitment to ethical trading principles and to set out the steps we are taking to tackle modern slavery and human trafficking in our business and in our supply chains.
The Company’s success depends not only on our technical ability, but also on our employees and wider workforce acting ethically. We are committed to complying with the applicable financial regulations and conduct rules that are prevalent in our industry, and also to creating a fair and transparent working environment within our business. This is demonstrated by our ‘Whistleblowing Policy’ and the ‘Values’ set out in our Employee Handbook.
We expect the same of our material suppliers and focus on developing relationships with these suppliers based on transparency. Although our material suppliers operate independently and in different industries, we recognise that their actions can impact our reputation. As such, we strive through our procurement due diligence processes and third-party supplier policies to select suppliers that share our values and demonstrate a commitment to the highest professional standards and ethical conduct in their business dealings. Our Director of Change oversees our procurement process.
The nature of the Company’s business is such that our material supply chain consists primarily of professional services suppliers: such as solicitors, administrators, surveyors, storage facilities, office supplies and technology providers, substantially all of whom are based in or operating from the United Kingdom. Consequently, we consider our supply chain to be low risk with regards to such relationships and ‘modern slavery’ and do not consider any further action to be necessary to mitigate the risk of "modern slavery" in the supply chain.
Our ‘Modern Slavery Act’ policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
We have not identified any areas requiring action with regard to such relationships beyond our regular procurement due diligence processes and our internal third-party supplier policy.
We are, however, committed to taking all appropriate steps to mitigate the risk of slavery or human trafficking taking place in our supply chain. We periodically review our procurement and supply chain management procedures with a view to further reinforcing this commitment.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide periodic training to our staff on a risk-based approach.