Modern Slavery Statement
This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Provident Financial plc and its operating companies during the year ending 31st December 2021, to prevent the possibility of modern slavery and human trafficking occurring within its direct operations and supply chains. All information and data provided below is based on the 2021 financial year unless otherwise stated.
Provident Financial Group plc and its operating companies (“PFG”) is a specialist lending business which operates across the United Kingdom (UK).
The total number of people employed by the PFG across its corporate office and three product divisions as at 31 December 2021 stood at 2,535. Collectively, these colleagues serve 1.6 million customers in the UK. PFG supplies credit cards and loans through Vanquis Bank and the Sunflower brand, and vehicle finance through the Moneybarn brand. PFG has operations in Bradford, Chatham, London, and Petersfield.
In 2021, the Group’s Consumer Credit Division, which operated under the Provident home credit and Satsuma brands, was closed down. As a result of this closure, the Group ceased to have any operations in the Republic of Ireland and was required to make redundancies across the Division. The Group, therefore, entered into a formal collective consultation process in 2021 with the 1,400 colleagues who worked in the Division’s nationwide network of branch offices, and the 700 colleagues who were based in the Bradford head office. Throughout this process, PFG supported all impacted colleagues through the redundancy process by ensuring that their wellbeing was looked after and giving them tools to find new employment opportunities. The final phase of the closure of the Consumer Credit Division was concluded on 31 December 2021.
The Group is committed to supporting and respecting human rights and, as such, is opposed to slavery and human trafficking in both its direct operations and in the indirect operations of its supply chains. As such, the Group will not knowingly support or do business with any organisation involved in slavery or human trafficking. This commitment is underpinned by the Group’s corporate policy on Human Rights and Modern Slavery which endorses the United Nation’s Universal Declaration of Human Rights and the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work. The Group also acknowledges the United Nation’s Guiding Principles on Business and Human Rights as the recognised framework for the Group and its Divisions to respect human rights in their own operations and through their relationships with other key stakeholders (e.g. suppliers) and is a signatory to the United Nations Global Compact. This is supported by the Group’s Procurement Policy which further underlines the Group’s commitment to complying with the requirements of the Modern Slavery Act 2015 and ensuring that procurement decisions take account of other sustainability considerations.
Other corporate policies, which support this commitment include the Health and Safety Policy, Whistleblowing Policy, Bribery Policy and Human Resources Policy.
Our supply chains
In 2021, the Group’s revenue was £602.6m and its annual procurement spend was £199.6m. Most of the Group’s tier-one suppliers are based within the UK. These suppliers range in size and scale from small and medium-sized enterprises to large multinational corporations. The highest area of spend for the Group is on professional services (consultants, contractors, etc), postage, credit card processing, customer referrals, data centre hosting, credit score checking services and consultancy and legal fees. Other areas of high spend include software licenses and support, contractor sourcing and recruitment, and property and facilities management.
The Group has well-established supplier due diligence processes and procedures to manage supply chain-based risks and ensure suppliers comply with the Group’s policy requirements and meet legislative requirements including those that relate to the Modern Slavery Act 2015. Across the Group, all new suppliers are assessed for the types of potential risks they pose and are sent questionnaires covering issues such as financial stability, data protection, information security, business continuity, regulatory compliance, and corporate responsibility (CR). Responses are assessed by subject matter experts. The CR questionnaire is sent to all materially important suppliers and includes establishing if the supplier’s turnover exceeds £36m and if so, to attach links to their modern slavery policy. If the supplier’s turnover is less than £36m they are asked to outline the processes they have in place to prevent instances of modern slavery and human trafficking arising in their supply chain and their direct operations.
The Group is a signatory to the UK Government’s Prompt Payment Code, which requires the business to pay suppliers within 60 days of receiving an invoice, and aim to pay all suppliers within 30 days of receiving an invoice.
The Group’s direct operations
In order to minimise the risk of modern slavery or human trafficking occurring within the direct operations of the Group (i.e. through the colleagues that are employed by the Group’s operating companies), a range of Human Resources processes and procedures are in place. Each of the Group’s operating companies is required to collect evidence which shows that: the person being hired is the person they claim to be; the prospective colleague has the right to work legally in the UK; the person has permission to do the type of work that is being offered to them and that they are not a criminal. This evidence is assured by conducting checks using information held on the National Fraud Database and by credit reference agencies, as well as through the carrying out of criminal record and driving licence checks. Prospective colleagues are also required to provide proof of ‘right to work’ documents in line with the Immigration, Asylum and Nationality Act 2006 and original photographic documents, for example, a valid passport. Colleagues are also encouraged to raise concerns relating to potential breaches of regulations, policy requirements and/or other grievances, either by contacting a line manager or by accessing the Group’s whistleblowing helpline ‘Safecall’ which is a 24-hour helpline, which is operated by an independent third party to ensure impartiality and confidentiality.
Our plans for the future
Throughout 2021, the Group has made significant progress in standardising the procurement processes and procedures that are employed across the business and has established and rolled out a Group-wide Supplier Management Framework. To support this colleagues will be provided with a Business Owners Handbook and two e-learning modules will be delivered in 2022 which will, among other things, underline the Group’s commitment to protecting human rights and minimising the risk of modern slavery or human trafficking of occurring indirectly in the operations of the suppliers that are engaged.
This statement is made pursuant to section 54(1) of the Modern Slavery Act and has been approved by the Provident Financial plc board of directors and will be reviewed and updated at least annually.
Malcolm Le May
Chief Executive Officer
Provident Financial plc