Snap Finance UK’s Modern Slavery and Human Trafficking Statement 2024
Introduction
This statement is made in accordance with the Modern Slavery Act 2015. It outlines the steps that Snap Finance UK has taken and will continue to take to ensure neither modern slavery nor human trafficking is practiced within the business or by its suppliers.
This statement applies to all Snap Finance UK and all associated entities where applicable.
The statement has been produced in accordance with The UK Modern Slavery Act 2015 (“MSA”), which came into force on 29 October 2015, and outlines the steps Snap Finance UK has taken to identify and address the risks of modern slavery to its supply chain and business operations.
About Snap Finance UK
Snap Finance UK is a financial services company that provides consumer loans to customers who may have difficulty obtaining credit through traditional lending channels. The company was established in the UK in 2017 and is based in Milton Keynes.
Snap Finance UK is a financial services provider that leverages unique technology to offer products to individuals. Providing consumers and retailers with a one-stop-shop for your borrowing and purchasing needs.
Our commitment to the Modern Slavery Act 2015
Snap Finance UK is committed to the principles and provisions of the Modern Slavery Act 2015, and the eradication of modern slavery. Snap Finance UK always conducts its business in compliance with all legislation and regulation, which are relevant to our business within the United Kingdom.
Snap Finance UK have internal policies, instructions, and governance demonstrating our commitment, requiring employees to raise concerns in relation to any identified or suspected non-compliance, and confirming that employees will not suffer any detriment for raising such concerns.
Related Policies
Snap Finance UK has a series of existing policies that collectively, and supported by underlying systems and processes, contribute towards the mitigation of the modern slavery risks that Snap Finance UK may face.
Anti-Bribery and Corruption Policy
Bribery and corruption, especially in supply chains, are risks that have contributed to the spread of modern slavery around the world. Without corrupt activity, including the acceptance of bribes, many of the conditions that lead or influence the extent of modern slavery may not exist.
Whistleblower Policy
Snap Finance UK’s Whistleblower policy encourages ethical conduct by providing mechanisms for any former or existing employee, or party associated with Snap Finance UK’s supply chain, to speak up and report actual or suspected wrongdoing. Unless individuals feel they can safely, and without consequence, report inappropriate conduct, that conduct would likely persist.
AML/CTF Program
Snap Finance UK understands that the prevention of money laundering and terrorism financing is a vital component of our efforts to mitigate modern slavery risks in our business. Money laundering in particular is closely related to modern slavery, as this activity can help to obfuscate funds that were generated through illegal activities such as human trafficking.
Employee Policies
Snap Finance UK’s employee policies help to ensure that all Snap Finance UK employees not only act in accordance with all relevant laws, but also with openness, honesty, fairness, and integrity. The employee policies underpin all of Snap Finance UK’s business operations and promote ethical business practices that mitigate the risk that any of Snap Finance UK’s business operations contribute to modern slavery and any other human rights abuses.
Our Supply Chains
In acknowledging the aims and abiding by the provisions of the Modern Slavery Act 2015, Snap Finance UK continuously maintain effective systems and controls to ensure that our supply chains are transparent and free from modern slavery.
We commenced work to enhance several internal processes to mature and centralise elements that will improve our controls and oversight of our supply chain and business operations.
Key internal policies, manuals and processes include but are not limited to:
- Underwriting and onboarding
- Authorisation
- Due Diligence
We follow a due diligence process to identify any modern slavery risk areas which require risk management action.
Reducing the risk of modern slavery is of high importance to Snap Finance UK. We are striving to continuously improve process and approaches for this.
Training
Snap Finance UK are committed to providing training on the importance of the Modern Slavery Act 2015, and ensuring modern slavery is not practiced within the business or by its suppliers.
All staff will undertake training which includes e-learning sessions facilitated by compliance, on employee’s responsibilities in recognising modern slavery.
Duty to report
It is the responsibility of all those working for or on behalf of Snap Finance UK, or under our control, to detect, report and prevent modern slavery from occurring within our business or supply chains. If there are any concerns or suspicions that modern slavery may be present in any part of our business or supply chains, all are encouraged to report it at the earliest possible stage to the compliance function.
To Whom does this apply
The above applies to all persons working for or on behalf of Snap Finance UK in any capacity, including all employees, partners, interns, contractors, external consultants, third-party representatives, and business partners, regardless of where they are operating. Any reported non-compliance with the Modern Slavery Act 2015, internal policies, instructions, manuals, processes, and governance will be investigated and may lead to disciplinary action and dismissal (employees) and immediate termination of contract (suppliers and contractors/consultants).