Modern Slavery and Human Trafficking Statement

Introduction From Our CEO

Slavery and human trafficking remains a hidden blight on our global society. We all have a responsibility to be alert to the risks, however small, in our business and the wider supply chain.

Organisation’s Structure

First Response Finance Ltd is a finance company primarily providing loans for the purchase of motor vehicles, along with a small number of personal loans for existing customers.  We are a wholly owned subsidiary of ITOCHU Europe PLC (ITOCHU) with its head office and business units in the UK. The company has an annual turnover in excess of £36m and a financial year ending on the 31st of March.

Training of Employees.

All employees receive annual training and assessment of understanding on compliance issues and our whistleblowing arrangements.

Conduct of Employees.

All employees are expected to comply with our code of conduct communicated to them through our Employee Handbook. Highlighted within this document is our expectation that staff report concerns and management are expected to act upon them.

Our Employee Handbook is available to all employees through our policy management tool Policy Hub.

Our Business

Our business is organised into the following business units:

• Head Office and Administration - Nottingham.
• New Business units - Nottingham and Glasgow.
• Existing Customers (New Business and Account Management) – Leigh.
• We have a hybrid working model where employees are able to work flexibly between the offices and their home.

Our Supply Chains

Our supply chains include approximately 3000 UK based motor dealerships supported by a small number of outsourced specialists within our operational areas along with management, information technology and office equipment suppliers.

Potential Risk Areas in Our Supply Chains

Given the nature of our business and that our relationships with our suppliers tend to be long-term, we believe that there is very little risk of slavery and human trafficking taking place and our risk-based processes reflect this.

Our Policies on Slavery and Human Trafficking

Our Modern Slavery and Human Trafficking statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Our Modern Slavery Statement is available to all employees through Policy Hub.

Due Diligence Processes for Slavery and Human Trafficking

As part of our initiative to identify and mitigate risk in this area; –

• We limit the geographical scope of our Lending to the UK.
• All introducing dealerships are regulated by the Financial Conduct Authority and based in the UK.
• We ask our suppliers of services and equipment for evidence that they adhere to the Modern Slavery Act 2015.
• Where possible we build long standing relationships with local suppliers of equipment and services, none outside the UK.
• We have in place systems to encourage the reporting of concerns and the protection of whistle blowers either to our own Compliance Team or Compliance Officer of ITOCHU.

Further information on how our outsourcing practices help us fight Modern Slavery can be found in our Outsourcing Policy. This is available to all employees through Policy Hub.

Supplier Adherence to Our Values

We have zero tolerance to slavery and human trafficking and expect all those introducing business to us and in our supply chain to comply with our values.

Our Effectiveness in Combating Slavery and Human Trafficking

• A robust due diligence process exists for all ‘Introducing’ dealers that includes a check to confirm they are authorised and regulated by the Financial Conduct Authority.
• Suppliers of services and equipment will be asked to confirm that they are adhering to the principles of the Modern Slavery Act and UK National Minimum Wage legislation.
• Where an employee of any of our business partners and suppliers have the need to raise genuine concerns about malpractice, they can do so by contacting our Compliance Help Desk during normal working hours.

Since we began to publish our annual statement, we have not had any instances of human trafficking or modern slavery reported to us internally or via our supply chains.

This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes our company's slavery and human trafficking statement for the current financial year.

Approved by the Board of Directors 30th March 2022 

Lisa Handley 

Company Secretary 

7th April 2022