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 2024.
About Simply
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.
Statement of Culture and Values
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.
Policies and Procedures
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
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 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.
Due Diligence and Risk Assessment
As part of our initiative to identify and mitigate risks, we outline our risk assessment and outsourcing requirements on our third-party providers in our Outsourcing Policy. This Policy ensures robust due diligence checks are carried out on suppliers before on-boarding. 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.
Our Outsourcing Policy also includes provisions 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.
People Processes
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.
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.
Steps Taken in the Financial Year 2024:
Simply published its first Modern Slavery Statement in the financial year ending 2023 and worked hard on ensuring it develops its Modern Slavery risk framework in 2024. We have taken the following steps in the financial year ended 2024 to combat slavery and human trafficking in our business and supply chain.
Further Steps
Simply will continue to evaluate whether further consideration is to be given on refining our risk frameworks to place more focus on anti-slavery and human trafficking strategies and whether there is sufficient integration of the risks into our existing money laundering control frameworks.
Simply will also continue to review our third-party outsourcing processes to ensure that our obligations under the Modern Slavery Act 2015 are passed down to our supply chain.
Declaration
This statement is published in line with section 54(1) of the Modern Slavery Act 2015 for the financial year 2024 and will be reviewed every year. This statement was approved by the board on 25 February 2025.
Ylva Oertengren
Chief Operating Officer, on Behalf of Simply Asset Finance Operations Ltd
11 March 2025