Introduction and Purpose
The Modern Slavery Act 2015 (the “Act”) came into force across the United Kingdom in 2015. The Act requires commercial organisations with an annual turnover of more than £36 million, to publish a slavery and human trafficking statement for each financial year.
This Statement sets out the Newable Group’s (Newable Ltd and its subsidiaries – “Newable”) compliance and commitment to the Act and its requirements. As required by the Act, this Statement sets out the steps taken during the financial year ended 31 March 2022 to combat slavery and human trafficking in our business and supply chains, and the further steps that we will continue to take.
Newable has a zero-tolerance approach to any form of modern slavery. Newable is committed to acting in an ethical manner, with integrity and transparency in all business dealings and is committed to putting effective systems and controls in place to safeguard against any form of modern slavery or human trafficking, taking place within our business, partnerships or supply chain.
Our commitment to our clients is very clear, we will always treat people in our businesses, partnerships or supply chain fairly. Newable expects its employees, suppliers and business partners to act responsibly and to comply with the requirements of this statement.
Our Business Activities
Newable’s purpose is to make a sustainable profit from helping other businesses to thrive, principally by providing services to UK Small and Medium Sized Enterprises (“SMEs”).
As a group, Newable’s strategy is to provide money, advice and workspace for clients. Newable also aims to make finance fairer, easier and more accessible to businesses. The legal entities that undertake lending and mortgage broking activity are authorised and regulated by the Financial Conduct Authority (FCA). The alternative funds business is an Appointed Representative of a Fund Manager that is also authorised and regulated by the FCA.
As a Group, Newable has in excess of 1,000 staff and most of our business is conducted within the United Kingdom, which Newable believes is a lower risk jurisdiction.
Our Partnership and Due Diligence Practices
Newable’s partners or suppliers are predominantly based in the United Kingdom. Our partners or supply chain includes business partners in the provision of mortgage services, alternative funds, office space, brokers, raw materials, manufactured products and distributors; and also providers of other services and goods necessary to run our business effectively.
Our employees who arrange significant contracts with partners or suppliers undertake a risk assessment process prior to the commissioning of any new partner or supplier, which considers slavery and human trafficking risks prior to entering into significant new partner or supplier contracts.
This process is supported by Newable’s Supplier Code of Conduct Statement (“the Code”) which sets out Newable’s expectations and requirements of its suppliers. This Code has been issued to all existing suppliers and to all new suppliers. The Code underpins Newable’s risk assessment of prospective suppliers and partners and sets out clearly Newable’s expectations of its suppliers and partners including how suppliers address and comply the requirements of the Modern Slavery Act.
In addition, Newable is currently strengthening its supplier risk assessment process and extending its periodic review of key suppliers to ensure on going compliance with Newable’s Code, including compliance with the Act.
All procurement is based on objective and fair criteria that reflect the principles of non-discrimination, equal treatment, transparency, procedural fairness, mutual recognition, proportionality and business efficiency.
In addition to carrying out due diligence on prospective partners or suppliers, as part of any tender process (where applicable) prospective partners or suppliers are expected to confirm their agreement to Newable’s contractual terms and conditions, confirm that they will comply with Newable’s policies and procedures and provide the services in accordance with all applicable laws and regulations. Newable expects its partners or suppliers to exercise due diligence along its partnership or supply chain.
Newable will, as soon as possible, end its relationship with a business partner if the supplier or business partner does not comply with these requirements or take alternative action if the supplier or business partner is not able to prove to Newable’s satisfaction, that it has implemented countermeasures to prevent comparable violations occurring in future.
Partners or suppliers will be requested to notify Newable prior to sub-contracting any significant services, and that they will ensure that any sub-contractors also comply with the Act. Newable will request the right to inspect / review partners or suppliers when deemed necessary, and to potentially terminate contracts based on any unfavourable results.
Newable treats its employees with respect and dignity and operates internal policies to ensure that it is conducting its business in an ethical, considerate and transparent manner.
Newable’s recruitment policies ensure that employee screening checks are carried out to ensure that the individual is legally entitled to work in the United Kingdom to safeguard against human trafficking or individuals being forced to work against their will and expects the same of each of its suppliers and business partners.
Employees are free to leave their employment after reasonable notice and are not required to lodge deposits of money or identity papers with their employer. The compensation and benefits paid to employees for a normal working week comply at least with guaranteed minimum legal requirements, including minimum wage legislation and working hours comply at least with the national legal standards and are not excessive.
Newable has a whistleblowing policy intended to encourage and enable employees to report suspected wrongdoing and raise serious concerns within the workplace. Newable is committed to ensuring that any employee concerns are taken seriously and investigated.
Further Steps and Employee Training
To ensure that there was a high level of staff awareness of issues relating to modern slavery and human trafficking, Newable required employees to complete modern slavery and human trafficking computer-based training when this policy was first introduced. In addition, all new staff are required to undertake this training. The training raises awareness and understanding of the changing expectations around human rights and modern slavery risks.
This Statement has been approved by the Board of Directors of Newable Ltd on (23rd November 2022), The Board will review and update it as necessary and at least annually.
Chief Executive Officer