SLAVERY AND HUMAN TRAFFICKING POLICY

Modern slavery is a crime and a violation of fundamental human rights. All types of modern slavery have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Access Financial group of companies are committed to acting ethically and with integrity in all our business dealings, relationships and recruitment processes to ensure modern slavery is not taking place anywhere within our business operations.

As a company, we ensure that our recruitment and selection processes are robust and that we compensate staff fairly and above the minimum wage for their contribution to the organisation. We also check that our business partners do not engage in any human trafficking or slavery activities and keep a record of such checks consistent with our disclosure obligations under the Modern Slavery Act 2015.

COMPANY DISCLOSURE REQUIREMENTS UNDER THE 2015 MODERN SLAVERY ACT

Commercial organisations subject to the 2015 Modern Slavery Act ('the Act') must report annually on the steps that they have taken during the financial year to ensure that slavery and human trafficking are not taking place in their own business or in their supply chains.

We expect high standards from all our business partners and have made this a contractual term in our service level agreements with them.

This policy applies to all staff directly engaged by the Access Financial group of companies including employees at all levels, Directors, agency or temporary staff and third-party representatives and business partners.

RESPONSIBILITY FOR THE POLICY

The Directors of the Company have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all individuals comply with it.

The HR Department has primary and day-to-day responsibility for implementing this policy for all directly employed Access Financial staff, but the Research & Development Department has responsibility for ensuring compliance from our business partners and for maintaining a checklist.

You must ensure that you read, understand and comply with this policy.

The prevention, detection, and reporting of modern slavery in any part of our business or if suspected within the organisations of our business partners is the responsibility of all. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You should immediately report any concerns regarding modern slavery and/or human trafficking immediately to the HR Manager or to a Director. If you are in any doubt whether a particular act or working condition in any of our offices or at those of our business partners may contravene any aspect of this policy then err on the side of caution and report it.

Access Financial has always encouraged open communication and we will support anyone who raises a genuine concern in good faith and in accordance with our policy even if they are mistaken. We are committed to ensure that no one suffers any detrimental treatment as a result of reporting in good faith, their knowledge, or suspicion, that modern slavery is taking place in any part of our business or that of our business partners.

COMMUNICATION AND AWARENESS OF THIS POLICY

Access Financial takes a zero-tolerance approach to modern slavery, a message that is communicated to all staff and business partners at the outset of any contractual agreement and as appropriate thereafter.

BREACHES OF THIS POLICY

Any employees found to breach this policy could face disciplinary action, which could result in dismissal for misconduct or gross misconduct. Relationships with other business partners would be immediately terminated if they breach this policy