Premium Credit Limited (PCL) is committed to carrying out business responsibly, which includes ensuring that slavery and human trafficking are not taking place in any part of the business or supply chain. This statement sets out PCL’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.
Organisational structure and supply chains
PCL is the market leading provider of insurance premium finance in the UK and Ireland. The Company also provides finance to pay annual fees such as accountancy and school fees. PCL is regulated by the Financial Conduct Authority in the UK, and the Central Bank of Ireland.
PCL employees approximately 400 people. Most UK employees are based on one site in Leatherhead, Surrey, and in addition there is a team of sales representatives who travel around the UK. There is also an Irish office in Dublin, where approximately 20 employees work.
Assessing and managing the risk
PCL has reviewed its own business and material suppliers, and assessed whether any risks of slavery or human trafficking arise. Risk is managed by using suppliers whom PCL consider to be reputable, and PCL has specifically requested that all material regular suppliers in these areas confirm that their own business activities do not involve slavery or human trafficking.
The supply chain is not extensive and is comprised mainly of outsourced services which include operations; IT support and development; and cleaning services. Other suppliers provide software. Most of the suppliers are UK based and there is one material supplier in India, which provides operations, and IT support and development.
PCL operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.
The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. PCL’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
Employee code of conduct
PCL’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour.
The organisation uses only specified, reputable employment agencies to source labour or provide services, and always verifies the practices of any new provider it is using before accepting workers or services.
PCL undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. PCL’s due diligence questionnaire has been updated to include relevant questions and considerations relating to modern slavery and human trafficking.
PCL has identified the following key performance indicators (KPIs) to ensure that good practices are maintained
Staff involved in procurement, supplier management and HR must complete training on modern slavery;
PCL evaluate potential suppliers before they enter the supply chain; and
PCL reviews all existing suppliers annually.
Training has been completed by targeted employees involved in procurement and management of supplier relationships including colleagues in IT, Finance, E-commerce, Marketing, Operations and the HR team.
Training includes how to assess the risk of slavery and human trafficking, how to identify signs and what steps to take if slavery or human trafficking is suspected. The focus is particularly on the expectations that PCL has of suppliers and contractors in maintaining an environment that is free from slavery and human trafficking.
Our continuing plan
Over the course of the next year, PCL will continue to engage with its suppliers and contractors to train appropriate colleagues and to promote awareness of policies throughout the company.
This statement is made with respect to the financial year ended 31 December 2016 in accordance with section 54(1) of the Modern Slavery Act 2015 and has been approved by the Premium Credit Limited Board. The statement will be reviewed and (if necessary) updated annually to reflect Premium Credit Limited’s ongoing commitment to ensuring that its business and supply chains are free from slavery and human trafficking.
Tom Woolgrove, Chief Executive Officer