ANTI SLAVERY STATEMENT
This statement is made pursuant to section 54, Part 6 of the Modern Slavery Act 2015 (the “Act”). The statement sets out the steps that Madison CF UK Limited trading as 118 118 Money (“118 118 Money”) has taken and our commitment to improving our practices to ensure that slavery and human trafficking is not taking place in our supply chains or any parts of our business. The Act and our publishing of this statement is intended to help customers, suppliers, and purchasers of services to make better, more informed choices about the products and services they purchase and the companies they support or do business with.
118 118 Money’s central position is that it should not be involved, directly or indirectly, for any reason, in the commission or facilitation of modern slavery and human trafficking, or any additional offences set out in the Act. 118 118 Money also expects its staff, business partners and supply chains to apply the same high standard, and to take reasonable steps to ensure other parties they do business with maintain the same high standards.
118 118 Money is affiliated to the well-known directory enquiries business 118 118, which launched in the UK in 2002 and soon became the largest and best-known provider of directory services in the UK. 118 118 and 118 118 Money both form part of the kgb group of companies, an international group operating in Europe, the Philippines and the United States providing information, financial services, e-commerce and contact centre services.
118 118 Money provides its customers with mid-term unsecured personal loans and personal credit cards, and has been providing these products to its customers since 2013 and 2018 respectively. 118 118 Money’s aim is financial inclusion through responsibly providing access to money with Simple, Transparent & Fair pricing, and serving customers through an intelligent digital first automated operating model.
OUR SUPPLY CHAINS
Customers can apply for our consumer credit products directly through our website, or via affiliate partners, price comparison websites and credit brokers.
We obtain and procure goods and services from various suppliers and business partners, primarily based in the UK but some internationally, including (amongst others): payment services; information technology hardware, software and related services; debt services; operational services such as for our website, our app, our systems and our telephone services; legal, financial, compliance and marketing services; and information security services.
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
118 118 Money is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships, implementing effective controls and processes, and applying a risk-based approach in seeking reasonable assurance that our business partners and/or supply chains are not involved in the commission or facilitation of modern slavery or human trafficking.
We also operate a Whistleblowing Policy which encourages and empowers our employees to identify and disclose details of any suspected modern slavery or human trafficking, either within our business practices, within our business partners or in any of our supply chains.
All such policies are available to our staff using our intranet sites, are explained to new staff as part of the onboarding process, and staff are encouraged to familiarise themselves with our policies as part of their employment.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk in this area, we carry out appropriate third party and customer due diligence, taking a risk-based approach when entering into business relationships with partners and suppliers. As part of our compliance due diligence in our third party management processes, 118 118 Money requests that prospective suppliers complete a self-assessment due diligence compliance check, with the extent of the checks proportionate to and dependent on the assessed risk level of the supplier. This self-assessment due diligence compliance check requires information relating to that supplier’s compliance with the Modern Slavery Act, including details of any required or voluntary modern slavery statements, their relevant policies and confirmation that they have a programme in place to ensure modern slavery and human trafficking does not exist in their business or supply chain. This includes a short-form due diligence questionnaire ensuring that all suppliers/partners at all levels, sizes and risk profiles provide due diligence information detailing their work to prevent modern slavery and human trafficking.
In addition to requesting further details on the above points, where suppliers are required to make their own statements in accordance with the Act, or confirm to us that they do so voluntarily, 118 118 Money will review the content of the statements published to ensure any modern slavery and human trafficking risks are being mitigated.
As set out further below, we have also started to introduce specific contractual obligations relating to the prevention and mitigation of modern slavery risks in some of our third party contracts.
We are a consumer credit services provider, who offers credit products to individual consumers. It is therefore possible that the risk of modern slavery and human trafficking may extend beyond our supply chains. As a lender, we have due diligence checks and criteria in place to reduce the risk of involvement in modern slavery or human trafficking, by implementing know your customer (KYC) checks and anti-money laundering checks when dealing with our customers and potential customers both at account opening and beyond.
TRAINING AND OUR EMPLOYEES
To ensure a high level of understanding of the risk of modern slavery and human trafficking, and as part of our employee induction and onboarding, we provide training on the requirements of the Act and direct our employees to our Policy for further information. We provide specific modern slavery training to all staff, on at least an annual basis, to ensure such staff are vigilant to the risks of modern slavery and human trafficking and take action where appropriate and necessary.
Our Human Resources team also have the responsibility to monitor and show that 118 118 Money’s own employees are recruited and treated within the confines of local laws and regulations, and are not a victim of any modern slavery or human trafficking offences arising from their employment.
Our Compliance, Legal and Information Security functions are responsible for our supplier onboarding due diligence, as part of our third party management processes, as well as for implementing internal policy changes relating to modern slavery/the Act.
UPDATES, GOALS AND KEY PERFORMANCE INDICATORS
118 118 Money shall update this statement annually, so please refer back to this page for future updates.
As a result of a change to our Designated Whistleblowing Officer, we have updated and refreshed our whistleblowing training and procedures, and telephone lines across our three main countries of operation, and communicated this to our employees to empower them to raise grievances and concerns. Staff are encouraged to report any instances of suspected modern slavery and human trafficking identified in any of 118 118 Money’s business practices, or those of its business partners or supply chains.
118 118 Money rolled out its modern slavery and human trafficking training to all staff over the year, and has reviewed and re-launched the compulsory annual training for all of its employees. 118 118 Money has also introduced a test as part of the training, to continue to ensure every employee understands and is reminded of their responsibility to identify, report and help prevent modern slavery and human trafficking at work and within our supply chains. We continue to include in contracts (where appropriate) obligations to ensure a supplier’s compliance with the Modern Slavery Act (or with applicable law which would include the Act).
This is to demonstrate our continued and further commitment to ensuring that risks of modern slavery or human trafficking within our business partners or any of our supply chains, are appropriately mitigated.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our modern slavery and human trafficking statement for the financial year ending 31 December 2022.
This statement was approved by the Madison CF UK Limited (t/a 118 118 Money) Board of Directors on 26 April 2023 and has been signed on behalf of the Board by Pradip Raval, Chairman.
05 May 2023