Modern Slavery & Human
Trafficking Statement

Introduction

HL Partnership Limited is committed to acting ethically and with integrity in respect of all its business activities. The Company adopts a zero-tolerance approach to modern slavery and human trafficking throughout all of its business dealings and expects its suppliers and relevant stakeholders to adopt a similar approach. In doing so, the Company endorses full compliance with relevant laws through the implementation and promotion of ethical business practices to protect workers from being exploited both within HL Partnership Limited and its supply chains.

This statement, which is made pursuant to Section 54(1) of the Modern Slavery Act 2015 for the financial year ending 31^st December 2020, outlines the potential risks and significant steps adopted by the Company to ensure that modern slavery or human trafficking does not occur in HL Partnership Limited and/or any of its supply chains.

This statement applies to all employees, workers or any persons working for us on our behalf in any capacity, including agency workers, contractors, external consultants, third-party representatives and business partners.

Organisational Structure and Supply Chain

HL Partnership Limited is a leading mortgage & protection network which aims to help Appointed Representative companies grow their businesses in a safe and compliant manner. We do this by providing firms with market-leading technology to help them find the most suitable products for their clients’ needs, and with first-class support strategies that minimise risk and ensure all firms meet their legal and regulatory requirements.

This statement relates to our financial year with our year ending on 31st December 2020 at which we had around 70 employees.

The Company currently provides its services in the UK only and we have two offices in Chichester and Leicester. Our supply chain connects mortgage lenders, insurance companies and other financial service providers with customers across the UK through our network of appointed representative firms.

Our supply chain comprises of the purchasing of goods and services that support the operation of our premises and the services we provide to our customers. Such purchases include office supplies, marketing resources, ICT equipment in addition to cleaning and waste products, office furnishings, security and catering supplies.

Pursuant to the Modern Slavery Act, HL Partnership Limited expects any and all suppliers / contractors with whom we conduct business to adopt similar high standards in the pursuit to prevent modern slavery or human trafficking by having a Modern Slavery and Human Trafficking statement or policy in place. The relationship with all our suppliers / contractors has been established over a number of years and is based on close working relationships and contact with the owners, directors and senior management of those businesses.

As and when the Company engages in business dealings with new suppliers / contractors, the Company undertakes due diligence to ensure there is no modern slavery or human trafficking activity occurring both within the business or any of its supply chains.

Responsibility

The Board of Directors has overall responsibility for ensuring this policy complies with the Company’s legal and ethical obligations, and that all employees comply with the policy. The Operations Director has responsibility for implementing and reviewing this policy and monitoring its use and effectiveness.

Relevant Policies

HL Partnership Limited several policies in place, which outline the Company’s approach towards the identification of modern slavery and human trafficking risks and any necessary steps to be taken to prevent slavery and human trafficking in its operations. These policies include:

Whistleblowing Policy – The Company encourages all its employees, workers or customers to report any concerns regarding any circumstances which may give rise to an enhanced risk of slavery or human trafficking. HL Partnership Limited’s Whistleblowing Policy enables workers to disclose information confidentially. For further information on this policy please refer to the full Whistleblowing Policy, available in the Staff Handbook.

Recruitment and Selection – The Company only uses specified, trustworthy employment agencies to source potential employees and always verifies the practices of any new agency used prior to accepting employees from that particular agency. HL Partnership Limited’s recruitment and selection procedures includes appropriate pre-employment screening of all potential employees to determine their right to work in the UK.

Equal Opportunities Policy – The Company provides a fair and equal working environment that is free from all forms of discrimination in all areas of employment. All employees are treated fairly with regard to protected characteristics; race, religion and belief, pregnancy and maternity, sex, marriage and civil partnership, disability, gender-reassignment, age, and sexual orientation. For further information regarding this policy, please refer to the full Equal Opportunities Policy, available in the Staff Handbook.

Due Diligence

HL Partnership Limited is actively undertaking due diligence when considering taking on new suppliers/contractors. The Company’s due diligence approach includes:

• Obtaining verification that any new suppliers / contractors have a Modern Slavery and Human Trafficking statement or policy in place;
• Ensuring any form of child labour or exploitation is not present in any part of the business or its supply chain;
• Providing protection for whistleblowers;
• Ensuring employees are paid at least the National Minimum Wage or National Living Wage, depending on their eligibility;
• Ensuring the absence of all forms of discrimination in any aspect of the business or its supply chain, including recruitment and selection procedures, access to training and promotions etc.;
• Ensuring right to work and pre-employment checks of all staff are conducted appropriately;
• Ensuring no harsh or inhumane treatment is allowed in any part of the business or its supply chain in line with the Company’s Equal Opportunities Policy;
• Using only specified, reputable employment agencies to source labour, and verifying the practices of any new agency prior to sourcing labour from that agency;
• Ensure staff are aware of the procedure to follow, should they have concerns regarding any circumstances which may give rise to an enhanced risk of slavery or human trafficking in any part of the business or its supply chain;
• Ensuring working hours are not excessive and are fully compliant with the Working Time Regulations 1998.

Continual Improvement

The Company will review and develop its policies, procedures, systems and controls to ensure it remains committed to preventing slavery and human trafficking in any part of its business or its supply chain.

HL Partnership Limited has not been informed of any incidents of slavery or human trafficking during the year, however, will investigate any allegations should they arise and take necessary action accordingly.

Board Approval

This statement has been approved by the Company’s Board of Directors in November 2020, they will review and update the statement annually.