This Modern Slavery Statement (this “Statement”) is made and published on behalf of Simply Asset Finance Operations Limited (“Simply”), pursuant to Section 54(1) of the Modern Slavery Act 2015 and is made with respect to the financial year ended 31 December 2023.
Simply Asset Finance Operations Limited is part of a group which is made up of different legal entities registered at the same address, namely SAF Group Holdco Limited; SAF Group Finance Limited; SAF1 Limited; SAF2 Limited; SAF3 Limited; SAF4 Limited; And SAF6 Limited (“SAF Group”). As such, any references to “Simply”, “we”, “us” or “our” in this Statement are references to Simply and any other company in the SAF Group.
Simply was founded in 2017 by a team of asset finance specialists to provide a range of flexible finance options to small and medium-sized British businesses, including hire purchase, finance leasing and asset equity release. Simply has now recruited over 150 people, in 4 offices, all based in the United Kingdom.
Simply’s partners are other specialist lenders, financial brokers and introducers. Our supply chain primarily includes businesses providing technology support, credit referencing agencies, and other ad hoc professional service providers, mainly based in or with branches in the United Kingdom.
Due to the nature of our business and the industry we operate in, we are generally assessed to have low risk of modern slavery in our business and supply chains. Nevertheless, Simply operates a zero-tolerance approach to modern slavery and human trafficking.
We are committed to improving our processes to ensure we are combatting such practices in our business and supply chain. Simply strives to maintain a culture of equality and transparency, whether in its own operations or throughout its supply chains and in its relationships with business partners. To that extent, we have and will continue to enforce effective systems and policies and measure and review our risk frameworks on a frequent basis, to ensure we always act ethically in our business dealings and relationships.
Our zero-tolerance approach to modern slavery is underpinned by a number of policies and procedures which ensure we are conducting business in an ethical and transparent manner, available to all our employees on Simply’s intranet, including but not limited to: Modern Slavery Policy, Outsourcing Policy, Equal Opportunity Policy, Whistleblowing Policy, Grievance Policy, ESG Policy, Anti-Bribery and Corruption Policy, Recruitment Policy and Health and Safety Policy.
These policies are reviewed frequently and kept up to date to ensure compliance with the relevant applicable laws and best practices.
As part of our initiative to identify and mitigate risks, we outline our internal due diligence procedures and risk assessment requirements on our third-party providers in our Outsourcing Policy. We have also employed technology solutions which facilitate risk reporting and guarantee that risks, including those related to modern slavery, are properly identified and mitigated.
When needed and based on the type of services we will be receiving, we advocate for the inclusion of modern slavery provisions in the agreement. Should the need arise to engage with service providers offering more labour-intensive services, we intend to perform a higher level of due diligence to avoid any inappropriate labour or modern slavery practices.
Apart from the above, one established policy Simply has abided by from day one is the fair compensation of all its employees and contractors. At a minimum, Simply offers all its employees a salary over the Living Wage as set by the Living Wage Foundation and provides them with organisational benefits. Our employment contracts give our employees the freedom to terminate their employment at any time and we do not force any of our employees or contractors to work overtime.
Our people management processes ensure that prospective employees or contractors are legally entitled to work in the United Kingdom and protect employees from any form of abuse.
We only deal with esteemed recruitment agencies, and we always aim that our contracts with these agencies include binding provisions that ensure they are committed to preserving the integrity of workers.
Although this is Simply’s first year publishing a Modern Slavery Statement, we have always been driven by equality and ensuring appropriate work conditions for all workers. To that extent, we would like to highlight the steps we have taken in the financial year ended 31 December 2023 to combat slavery and human trafficking in our business and supply chain.
1. Creating a Modern Slavery Policy
In order to clearly establish our stance on slavery and commitment to combatting it, we have implemented a Modern Slavery policy (the “Policy”). The Policy outlines Simply’s employees, contractors, service providers, suppliers and business partners’ responsibilities in tackling modern slavery and ensuring Simply meets the highest ethical standards of integrity in its business dealings.
2. Anti-Slavery & Human Trafficking Provision in our Broker Agreements
In response to the growth in our partnerships and the expansion of our broker pools, we decided to amend our broker agreements to include modern slavery provisions which include, among other things, the obligation on our brokers to comply with all applicable anti-slavery and human trafficking laws and to notify Simply of any breach thereof. We therefore have now made it clear that we expect the same standard of transparency and commitment to battling modern slavery from our brokers.
3. Updating our Outsourcing Policy
In order to ensure we are only outsourcing to compliant service providers and suppliers, we have added supplementary provisions to our Outsourcing Policy on review levels, due diligence and risk reporting applicable to contracts with third party providers. This includes, among other things, indicating on the digital report whether the supplier is compliant with the Modern Slavery Act.
4. Updating our Culture Metrics
As part of our continuous strive to ensure a healthy culture at Simply, we have implemented culture metrics which address social sustainability and which we monitor on a monthly basis during our Risk and Governance Committee meetings.
Simply intends to take further actions in the financial year ending 31 December 2024, to ensure it continues to mitigate the risk of modern slavery in its business:
This statement is published in line with section 54(1) of the Modern Slavery Act 2015 for the financial year ended 31 December 2023 and will be reviewed every year. This statement was approved by the Board in its November 2023 board meeting.
Chief Operating Officer, on Behalf of Simply Asset Finance Operations Ltd
29 January 2024