Introduction

This statement sets out L&C’s 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 1 January 2022 to 31 December 2022.

At L&C, we want to take the same approach to combating modern slavery as we do for delivering exceptional customer experiences. Therefore we are committed to preventing slavery and human trafficking in corporate activities, and to ensuring that supply chains are free from slavery and human trafficking.

This encompasses looking for new ways to tackle modern slavery, and really challenge everyone we interact with to take action. That’s why we welcomed the Independent Anti-Slavery Commissioner’s review within the financial services sector on ‘Preventing Modern Slavery and Human Trafficking’. We are reviewing the outputs of the recommendations and will evolve our approach, aligned to these.

During the next year, our focus will be on educating our people, equipping them with the tools to best support the customers, businesses and suppliers we work with.

Organisational structure

London & Country Mortgages was first established in 1985 as a wholly owned subsidiary and appointed representative of Chase de Vere Investments Plc. The company has quickly grown to provide expert mortgage advice and provides mortgage best-buy tables for many national press titles. The Company is frequently asked to comment on mortgage issues and regularly contributes to the national media. On 18th October 2000 Chase de Vere Investments Plc sold London and Country Mortgages Ltd to M R Edge. London & Country Mortgages had its application for Authorisation granted by PIA on 20th October 2000 and relinquished its status as an appointed representative of Chase de Vere Investments Plc on 23 November 2000. London & Country Mortgages Limited is regulated by the Financial Conduct Authority. In January 2018, Experian acquired 25% of the L&C shares, signaling the start of a strategic partnership to accelerate L&C’s digital investment programme. The aim of the programme is to provide the most efficient and consumer centric mortgage advice process in the UK.

It is the Company’s policy to maintain a strong corporate culture and identity, attracting quality customers and staff, building long-term value into the business. The Company is committed to providing the highest quality of thoroughly researched financial advice, which is professional, efficient and user friendly.

The Company currently has offices in Bath, Newcastle and London.

Supply chain and Supplier Due Diligence

L&C’s supply chains are mainly in respect of recruitment, the procurement of office supplies, materials and equipment, and the provision of professional and support services, principally in relation to IT, facilities, finance, human resources and marketing. We seek to engage with suppliers who are reputable and well established within financial services, and who are demonstrating compliance with modern slavery legislation.

In order to support our statement, we aim to build relationships with reputable suppliers to ensure expectations of business behaviour are both clear and consistent; and we expect our direct suppliers to have suitable anti-slavery and human trafficking policies.

In terms of Human Resources procedures, we have rigorous identity and background checking in place and work with carefully selected and reputable third parties to source candidates. Once in employment, we encourage a culture of speaking up about any concerns. Key policies and initiatives include:

  • Anti Bribery and Corruption policy
  • Whistle blowing (Speak Up) policy
  • Recruitment of foreign workers policy
  • Equal opportunities and anti harassment policy
  • Grievance policy
  • Health and Safety policy
  • Free confidential helpline to employees
  • Help @ hand
  • Anti Money Laundering and Counter Terrorist Financing Policies

Modern Slavery Risk Assessment

Whilst due to the nature of our business we consider that L&C remains low risk from a modern slavery perspective we remain vigilant and are paying particular attention to the following parts of our business in our assessment of Modern Slavery Risk.

Our UK direct supply chain which is 100% UK procured may result in services such as IT support and Software development being delivered from overseas locations.

We are increasingly using employment agencies to bring in employees as our business grows on a full time, part time and temporary basis.

Training

The Modern Slavery Act requires all company colleagues to consider the relationship that they have with other companies and to be alert to the possibility of slave labour and/or human trafficking. We are in the process of designing a training module to teach employees about the risks of Modern Slavery as well as incorporating the training into our staff induction.

Measuring Effectiveness

We are still in the process of developing steps and these will be kept under review with a view to ensuring that the following criteria are met in advance of the publication of the next statement.

  • Implementation of an employee training module on modern slavery which will cover the basic principles and be delivered to those responsible for working with suppliers. This will educate our people equipping them with the tools to best support the customers and suppliers we work with.
  • Modern slavery training incorporated into our induction training.
  • Any reports or concerns or risks relating to modern slavery and human trafficking are tracked and reported to Senior Management and resolved.

All new contracts with suppliers should include clauses which address the parties’ obligations.

Monitoring and Reporting

If issues are identified in relation to modern slavery and/or human trafficking, these will be reported to the Human Resources Director.

More general issues in relation to the running of the statement will be reported back to the Human Resources Department.

This statement has been approved by the company’s board of directors, who will review and update it annually.


Signed by David Gray, Human Resources Director