2020 was the first year that Bamboo published a statement under the Modern Slavery Act 2015 (the “Act”). The statement is reviewed annually to ensure it reflects our procedures and processes fully.
To date we have had no reports of slavery or human trafficking within our organisation or that we have been made aware of such occurring within our supply chain or the third parties we are working with. We remain vigilant and are continuously looking at ways we can further improve our controls and protect all lives within our business eco-system.
Bamboo’s Modern Slavery Statement reflects our established practices and future intended action pursuant to section 54 of the Act. This statement is to let our customers, colleagues and any other third parties know what Bamboo is actively doing to prevent modern forms of slavery or human trafficking taking place within the business eco-system (of supply chains and industry partners) that we operate in.
Our UK Business
We are a UK only financial services business. We started lending to consumers in 2014. We have built our business around helping customers access sustainably affordable loans. Our loans are risk price adjusted to our customers credit profiles. We have over 100 colleagues, almost all based in the UK: in Southampton, London. We outsource part of our function to a third party located in Caerphilly, Wales. Everyone, including those located in Caerphilly are vetted, including right to work in the UK checks.
All of the salaries are at the level or above the one set by the UK’s Living Wage Foundation.
We do not undertake any business outside the UK, but we do contract and conduct business with non-UK suppliers and counterparties, which generally fall into one of the following categories: Technology Infrastructure, Professional Services or Software supply. We recognise the complex nature of supply chains for goods and services and are vigilant when it comes to those relationships. We are authorised and regulated by the Financial Conduct Authority.
We are proud to serve our customers and seek to earn their trust and respect in everything we do and how we do it. This includes ensuring that where our business touches or affects other lives, in our daily dealings and through our supply chains and industry partners, we are confident that we do not directly or indirectly compromise human dignity or unwittingly support modern forms of slavery or human trafficking.
Given the nature and location of our UK lending and the business eco system we operate in, we do not consider that the activities we engage in are particularly prone to or are a target of modern forms of slavery and human trafficking and rate the risk as low. However, we are not complacent, and we are committed to taking our responsibilities seriously and fully supporting the Government’s objectives to eradicate these inhuman practices.
To that end:
- we carry out careful risk based due diligence on the parties we work with before any contract or other arrangements are entered into and thereafter monitor them on an ongoing basis, in line with our Contracts Policy. If any such due diligence identifies a potential risk of a counterparty exposure to modern slavery or human trafficking our Legal & Compliance team are immediately involved;
i) counterparties in high risk territories or industry sectors; and
ii) our major counterparties,
we seek specific confirmations of compliance with the Act. Bamboo will terminate arrangements with any such counterparty that is not prepared to provide such confirmations;
- we undertake employee education to help them develop a good understanding of the modern form of slavery and human trafficking risks and ensure awareness of the need for vigilance in our dealings with our counterparties, potentially our customers and supply chains. Our colleagues also receive anti-money laundering and bribery training on an annual basis to help them understand the wider picture surrounding human slavery and highlight the risks;
- our colleagues are encouraged to raise any suspicions or concerns about any wrongdoings or breach of legal requirements by any of our counterparties they deal with both generally and specifically in respect of the Act via our Whistleblowing procedure; and
- our internal Quality Assurance team reviews calls and can provide feedback on any suspicions of forced labour during interactions with our customers.
This statement is issues pursuant to section 54 of the Act and relates to the financial year ending 2023. This statement has been formally approved by the Board of Bamboo Limited and signed on their behalf.