Policies & legal
|
4 min read

Modern Slavery Policy

Published pursuant to section 54 of the Modern Slavery Act 2015

Introduction

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps taken by Loans 2 Go Limited t/a BufferMoney (‘the Firm’) during the financial year to reduce the risk of modern slavery and human trafficking within its business and supply chains.

The Firm recognises that modern slavery is a criminal offence and a serious violation of fundamental human rights. The Firm is committed to operating responsibly and ethically and to maintaining appropriate systems and controls designed to reduce the risk of modern slavery within its operations and supply chain.

The Firm has a zero-tolerance approach to slavery, servitude, forced labour and human trafficking.

Our Business

BufferMoney is a trading name of Loans 2 Go Limited, registered in England and Wales (Company Number 04519020). The Company is authorised and regulated by the Financial Conduct Authority (Firm Reference Number 679836).

Loans 2 Go Limited t/a BufferMoney provides unsecured personal loans to retail customers within the United Kingdom. The Company operates solely within the UK and employs staff across operational, compliance, finance and administrative functions.

We recognise that modern slavery exists in many forms across many industry sectors and we are committed to act ethically and with integrity in all our business relationships and are opposed to slavery and human trafficking in our direct operations and in the indirect operations of our supply chain. As such, we will not knowingly support or do business with any organisation or individual involved in slavery or human trafficking.

As a financial services provider, we have relatively straightforward supply chains compared with those of other sectors, with the majority of procurement being sourced from suppliers based in the UK. However, we consider that in certain geographical locations within the UK, the cheque cashing and pawnbroking services offered to our customers may increase our exposure to transacting with those involved in slavery and/or human trafficking.

Supply Chains

As a regulated financial services provider, the Firm’s supply chains are primarily service-based. The Firm’s supply chain includes:

recruitment agencies,
credit reference agencies,
fraud prevention agencies,
payment service providers,
third-party debt collection agencies,
legal and professional advisers,
Open Banking and affordability verification providers, and
IT, hosting and analytics providers.

The Firm recognises that outsourced and intermediary service providers may present a higher exposure to modern slavery risk and these relationships are considered within the Firm’s due diligence processes.

Policies and controls

The Firm maintains policies and procedures relevant to modern slavery risk, including:

Modern Slavery and
Human Trafficking Policy,
Whistleblowing Policy,
Recruitment Policy,
Anti-Financial Crime Policy,
Anti-Money Laundering Policy, and
Vulnerable Customer Policy.

Policies and procedures are reviewed periodically and updated where appropriate.

Due diligence

The Firm takes a proportionate and risk-based approach to supplier and recruitment due diligence. This may include:

right-to-work checks for employees,
oversight of recruitment agencies,
proportionate supplier due diligence where appropriate, and
escalation procedures for concerns identified by employees.

Where concerns are identified, the Firm may require remediation actions, suspend engagement or terminate supplier relationships where appropriate.

Employees

Loans 2 Go Limited t/a BufferMoney is committed to treating employees fairly and in accordance with UK employment legislation. The Firm operates recruitment and onboarding procedures which include identity and right-to-work verification checks.

Employees:

receive written terms of employment,
are paid in accordance with applicable wage legislation, and
have access to grievance and whistleblowing

Employees are free to leave employment subject to normal contractual notice provisions and are not required to surrender identity documents or pay recruitment fees.

Training

Relevant employees receive awareness training on modern slavery risks and reporting procedures.

Governance

Responsibility for oversight of the Firm’s modern slavery framework sits with the Board of Directors.

Approval

This statement has been approved by the Board of Directors of Loans 2 Go Limited t/a BufferMoney and constitutes the Firm’s modern slavery and human trafficking statement for the relevant financial year in accordance with section 54 of the Modern Slavery Act 2015.

This statement is published on the Firm’s website in accordance with the Modern Slavery Act 2015.