This statement sets out the steps CarFinance 247 Ltd and 247 Money Group Ltd ("CF247”) has taken and will continue to take to ensure slavery and human trafficking does not take place in any part of its business.
CF247 has a zero tolerance approach to slavery and human trafficking and this policy has been produced pursuant to Section 54 of the Modern Slavery Act 2015. CF247 expects its suppliers and their supply chains to adopt all reasonable and practical steps to comply with the Modern Slavery Act 2015.
This statement does not form part of any employee's contract of employment so may be amended from time to time.
CF247 is a leading UK online car finance broker and lender. The Group is organised into two divisions: CarFinance 247 Ltd and 247 Money Group Ltd.
Due Diligence Process for Slavery and Human Trafficking
CF247 employees are based in the UK. Employee relations are managed consistently across the Group by the Human Resources department. All relevant colleagues are paid at least the UK National Minimum Wage.
Services procured through third parties are in the process of being grouped into tiers, based on value, importance and risks to CF247. This will allow us to identify which of our service providers we should focus the most attention on.
We will be writing to suppliers seeking assurance that the principles of the Act are being followed/adopted, though clearly expecting a more complete and robust attestation from those few suppliers who directly fall under the Act. Where no assurance is forthcoming, we will engage with those parties at contract review to ascertain whether there is sufficient concern to replace them.
Additionally, we are in the process of supplementing this policy with a Supplier Code of Conduct which will reflect our existing commitment to operate ethically and with integrity in all our business relationships. The implementation and enforcement of effective systems and controls within the organisation and our supply chains will safeguard against slavery and human trafficking.
Risks to the CF247 associated with the Act are managed in accordance with the Group’s Risk Management Framework. Additionally the Group operates a Whistleblowing Policy and actively encourages the reporting and exposure of unethical behaviour.
Responsibility for this Policy
The Board of CF247 has overall responsibility for ensuring this policy complies with our legal and ethical obligations. CF247 encourages all of its employees, consultants, workers and contractors to report any concerns they have about slavery and/or human trafficking affecting the business, even if they turn out to be mistaken.
Steps for the Prevention of Modern Slavery
All suppliers, contractors and other business partners will also be made aware of CF247's zero tolerance approach to modern slavery and will be expected to adopt the same approach.
The following internal policies are also in place, or are being developed, to monitor and reduce the risk of modern slavery and human trafficking in our business:
- Third Party Due Diligence Policy;
- Whistleblowing Policy;
- Financial Crime Policy;
- Health and Safety Policy.
We regularly consider the level of risk of slavery and human trafficking pose to CF247, its suppliers, contractors and business partners and given the nature of the companies in our supply chain, we consider this risk is very low.