Modern Slavery Act Statement 2018

Modern Slavery and Human Trafficking Statement for the Financial Year to 31st December 2018

INTRODUCTION FROM THE CHIEF EXECUTIVE OF CABOT CREDIT MANAGEMENT GROUP

The Cabot Credit Management group of companies takes its social responsibilities seriously and conducts its business in accordance with an ethical, values driven culture. We are therefore committed to understanding more about modern slavery and improving our practices to ensure that slavery and human trafficking are not present in our business or within our supply chain.

Our Group’s Organisational structure:

This statement is made on behalf of the following UK-based group operations Cabot UK Holdco Limited, Cabot Credit Management Group Limited, Cabot (Group Holdings) Limited, Cabot Financial (Europe) Limited, Wescot Credit Services Limited, Orbit Debt Collections Limited and Mortimer Clarke Solicitors but all principles, policies and processes are or will be disseminated to our overseas group companies including Cabot Financial Ireland, Cabot Financial France and Cabot Financial Spain.

 

OUR SUPPLY CHAINS

We procure a wide range of goods and services from a variety of suppliers. Our supply chains currently support the following activities:

Debt collection

Call centre support

Printing and Print distribution

Recruitment and training

Advertising and marketing

IT services

Legal services

Data analytics

Operations and infrastructure support

Business process outsourcing

The Group adopts a risk-based approach to the assessment of our business and supply chain, which involves taking geographical, industry and market factors into account in order to identify categories of supply that may present a higher risk of modern slavery being present.

ACTIONS TO ADDRESS RISK

As part of our initiative to identify and mitigate risk we have undertaken, or are in the process of undertaking the following actions:

building the assessment of slavery and trafficking risk into our supplier sourcing, due diligence and on-boarding programmes;

reviewing and assessing existing suppliers, and in particular their sourcing policies in key risk areas;

monitoring potential risk areas in our supply chains; and

protecting whistle blowers.

We have chosen suppliers that operate under recognised ethical codes of conduct that include regular compliance audits and we only work with companies that contractually commit to complying with applicable laws and regulations.

OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. To this end, in addition to reviewing and updating all policies that touch on identified areas of risk we have developed and implemented a stand-alone Modern Slavery and Human Trafficking Policy that 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.

FURTHER STEPS

During the next phase of our programme we intend to take the following additional steps:

Implementation of processes for identifying, assessing, mitigating and reporting specifically on modern slavery risks in the business;

Development and implementation of staff training;

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year to 31st December 2018.

Ken Stannard

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The Cabot Credit Management Group incorporates: