This statement sets out the Business & Enterprise Finance Ltd’s group (BEF) 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. This statement relates to actions and activities during the financial year April 2022 to 31 March 2023.
As part of being a Community Development Financial Institution, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking.
Our organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Organisational structure and supply chains
This statement covers the activities of BEF:
• Our organisation provides flexible finance solutions to businesses, helping them grow and improve the wealth of the economy and the communities we serve. We lend to both new and established organisations across all sectors.
We only operate in the UK.
High Risk Activities
Due to the nature of our pre-employment checks for all new starters due to the regulatory requirements of the Organisation we believe that we are able to minimise high-risk activities linking to the employment of BEF staff.
Sub-contractors may prove to be higher risk activities because we are reliant on the subcontractor carrying out the necessary and relevant checking process.
Responsibility for our anti-slavery initiatives is as follows:
- Policies: Chief Executive, Compliance Manager and HR Manager put in place and review all policies regularly, adhering to a policy review tracker. The progress of the reviews has oversight by FARC.
- Risk assessments: The organisation places great emphasis on its responsibility for human rights and modern slavery risk analysis. All concerns or complaints are subject to a full investigation and risk analysis. The organisation deems the risk to be small but ensures that appropriate checks are in place to protect the organisation from the risk. See risk register.
- Investigations/due diligence:
The Chief Executive, Compliance Manager and HR Manager as a panel are responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking.
- Training: All staff complete an annual on-line training module, to equip them with the tools to better understand and respond to the identified slavery and human trafficking risks.
We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
- Whistleblowing policy: We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can complete our confidential disclosure form.
- Employee code of conduct: Our code makes clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour.
- Subcontractor code of conduct:
We are committed to ensuring that its subcontractors adhere to the highest standards of ethics. Subcontractors 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. Any serious violations of our subcontractor code of conduct will lead to the termination of the business relationship.
- Recruitment/Agency workers policy: We use only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
We undertake due diligence when considering taking on new suppliers and subcontractors and regularly review its existing relationships. Our due diligence and reviews include:
- evaluating the modern slavery and human trafficking risks of each new supplier
- participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking
- invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.
We require all staff to complete an online training course during their probationary period and as part of their annual on-line training requirements.
As well as training staff, we have raised awareness of modern slavery issues by putting up posters across our premises and circulating a series of emails to staff.