Slavery & Human Trafficking Statement

Modern Slavery and Human Trafficking Statement

Introduction from our CEO

Slavery and human trafficking remains a hidden blight on our global society. We all have a responsibly to be alert to the risks, however small, in our business and the wider supply chain. Staff are expected to report concerns and management are expected to act upon them.

Organisation’s Structure

We are a Finance Company primarily providing loans for the purchase of motor vehicles along with a small number of personal loans for existing customers.  First Response Finance Ltd is a wholly owned subsidiary of ITOCHU Europe PLC (ITOCHU) with its head office and business units in the UK. The company has an annual turnover in excess of £36m and a financial year ending on the 31st March.

Training of Employees.

All employees receive annual training and assessment of understanding on compliance issues and our whistleblowing arrangements.

Our Business

Our business is organised into four business units:

  • Head Office and administration - Nottingham
  • New Business Units - Nottingham & Glasgow
  • Existing Customers (New Business and Account Management) - Leigh


Our Supply Chains

Our supply chains include UK based motor dealerships supported by a small number of outsourced specialists within our operational areas along with management, information technology and office equipment suppliers.

Potential Risk Areas in our Supply Chains

Given the nature of our business we believe that there is a very little risk of slavery and human trafficking taking place and our risk based processes reflect this.

Our Policies on Slavery and Human Trafficking

Our Modern Slavery and Human Trafficking statement 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.

Due Diligence Processes for Slavery and Human Trafficking

 As part of our initiative to identify and mitigate risk in this area; –

  • We limit the geographical scope of our Lending to the UK
  • All introducing dealerships are regulated by the Financial Conduct Authority and based in the UK.
  • Where possible we build long standing relationships with local suppliers of equipment and services, none outside the UK.
  • We have in place systems to encourage the reporting of concerns and the protection of whistle blowers either to our own Compliance Team or Compliance Officer of ITOCHU.

Supplier Adherence to our Values

We have zero tolerance to slavery and human trafficking and expect all those introducing business to us and in our supply chain to comply with our values.

Our Effectiveness in Combating Slavery and Human Trafficking

  • A robust due diligence process exists for all ‘Introducing’ dealers that includes a check to confirm they are authorised and regulated by the Financial Conduct Authority.
  • Suppliers of services and equipment will be asked to confirm that they are adhering to the principles of the Modern Slavery Act and UK National Minimum Wage legislation.
  • Where an employee of any of our business partners and suppliers have the need to raise genuine concerns about malpractice they can do so by contacting our Compliance Help Desk during normal working hours.

Since we began to publish our annual statement we have not had any instances of human trafficking or modern slavery reported to us internally or via our supply chains.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our company's slavery and human trafficking statement for the current financial year.

Approved by the Board of Directors 24th May 2018.

John Fellows
Company Secretary
30th June 2018