Modern Slavery Statement

The Group’s business is lending money to registered providers of social housing in the United Kingdom, funded through the issue of bonds and raising bank loans. The Group offers various financial instruments through wholly owned subsidiary vehicles and certain affiliated companies, the structure of which can be found in the Group’s latest annual report.

The Group and its customers operate entirely in the United Kingdom and the Group’s primary activity is supported by banks and professional firms based in the United Kingdom or European Union. The Group engages suppliers for products and services across areas such as computing, design, security, office maintenance and professional consultation. The Group’s suppliers are primarily based in the United Kingdom, with some larger firms such as banks and retail vendors having international presence.

The Group does not sell or donate any physical items requiring manufacture from raw materials, though will from time to time instruct promotional materials to be made.

Given the nature of our business model, we assess our inherent exposure to modern slavery risk as relatively low compared with organisations with extensive manufacturing or logistics operations; however, we recognise that modern slavery can occur in any sector and remain vigilant in relation to our own operations, our suppliers and relevant financial counterparties.

The Group maintains various internal policies which are available to all staff. Those relevant to the prevention of modern slavery and human trafficking are:

– Anti-Bribery Policy and Code of Conduct
– Modern Slavery Policy
– Whistleblowing Policy

Training on the subject matter of these policies is a mandatory part of the onboarding process, with refresher training required every year. The training modules are available for staff to revisit at any time.

The outcome of the Group’s latest risk assessment is that the Group is at low risk of having incidents of modern slavery and human trafficking in its operations and supply chain.

The outcome of the Group’s latest supplier audit found that all suppliers which met the statutory threshold to publish a modern slavery statement had done so, and that all suppliers which did not have a published statement were exempt from the statutory requirement.

The Group requires that suppliers exempt from publishing a modern slavery statement confirm their commitment to the Group’s modern slavery policy, under which any supplier found in breach of this policy may cause the supplier relationship to be terminated.

In line with emerging expectations for the financial services sector, we also consider modern slavery and wider human rights risks, where relevant and proportionate, in our lending and investment due diligence and ongoing relationship management.

Since the publication of the last modern slavery and human trafficking statement, the Group has reviewed its reporting in compliance with refreshed government guidance, focusing on clarity, transparency and actions taken.

The Group renews its commitment to monitoring and updating its risk assessments and reporting in relation to modern slavery and human trafficking, maintaining its standard of supplier due diligence, and continuing to deliver regular training to staff around the relevant risks and the responsibilities of the Group and every associated individual.

We monitor the effectiveness of our approach through a combination of indicators, including training completion rates, coverage of our supplier base by modern-slavery due diligence activities, and any concerns raised through our Whistleblowing or other reporting channels. We will keep these measures under review and develop them over time as our approach matures.

This statement, and the actions described in it, are reviewed annually.