This Statement is for Premium Credit Limited and Mizzen Mezzco Limited, who for the basis of the Statement will be described collectively as PCL.
PCL is committed to carrying out business responsibly, which includes ensuring that slavery and human trafficking are not taking place in any part of the business or supply chain. This Statement sets out PCL’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business or its supply chains.
1.0 Organisational structure and supply chains
PCL’s purpose is clear; “We proudly support our community of customers and partners in creating opportunities through convenient payments”. PCL is a market-leading provider of insurance premium finance in the UK and Ireland.
The Company also provides finance to pay annual fees such as accountancy and school fees. PCL supports over 3,000 intermediaries in its chosen markets and serves more than 2.1 million customers. PCL is regulated by the Financial Conduct Authority in the UK, and the Central Bank of Ireland.
PCL employs approximately 400 people. Most employees are based on one site in the UK in Leatherhead, Surrey, and in addition there is a team of sales and compliance representatives who travel around the UK. There is an Irish office in Dublin, where approximately 20 employees work. Approximately 140 people were employed overseas in India and South Africa during 2020 providing outsourcing services to PCL. The South African services were returned to the UK in March 2021 which will reduce the number of people employed overseas by approx. 25%.
2.0 Assessing and managing the risk
PCL has reviewed its own business and material suppliers and assessed whether any risks of slavery or human trafficking arise. Risk is managed by using suppliers whom PCL considers to be reputable, and PCL has specifically requested that all material regular suppliers in these areas confirm that their own business activities do not involve slavery or human trafficking.
The supply chain is not extensive and is comprised mainly of outsourced services, which include business processing operations; IT support and development; facilities and cleaning services. Other suppliers provide software. Currently Premium Credit outsource business processing operations and IT Development to a company in India. The service has extensive oversight that incorporates adherence to all policies including this one. Second line risk management teams also conduct an annual review to ensure effectiveness of our controls.
3.0 Relevant policies
PCL operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
4.0 Due diligence
PCL undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. PCL’s due diligence questionnaire includes relevant questions and considerations relating to modern slavery and human trafficking.
All employees responsible for procurement and management of supplier relationships receive training every two years. This includes the Executive team and employees in IT, Finance, E-Commerce, Marketing, Operations and the HR. Colleagues in relevant roles at the outsourced providers also complete the PCL training.
Training includes how to assess the risk of slavery and human trafficking, how to identify signs and what steps to take if slavery or human trafficking is suspected. The focus is particularly on the expectations that PCL has of suppliers and contractors in maintaining an environment that is free from slavery and human trafficking.
6.0 Performance indicators
PCL has identified the following key performance indicators (KPIs) to ensure that good practices are maintained:
7.0 Our continuing plan
Over the course of the next year, PCL will continue to engage with its suppliers and contractors, to train appropriate colleagues and to promote awareness of policies throughout the company.
This Group Statement is made with respect to the financial year ended 31 December 2020 in accordance with section 54(1) of the Modern Slavery Act 2015 and has been approved by the Premium Credit Limited Board on 27 April 2021. The Statement will be reviewed and (if necessary) updated annually to reflect Premium Credit Limited’s ongoing commitment to ensuring that its business and supply chains are free from slavery and human trafficking.
Tara Waite, Chief Executive
30 April 2021