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Modern Slavery Statement

Liverpool Commercial Finance
49 Jamaica Street, Liverpool L1 0AH
Email: admin@liverpoolcommercialfinance.co.uk

Financial Year: [Insert Financial Year]
Published: October 2025

1. Introduction

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that Liverpool Commercial Finance has taken to ensure that modern slavery and human trafficking are not taking place in our business or supply chains.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Liverpool Commercial Finance is committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

2. Our Business and Organisation Structure

Liverpool Commercial Finance is a commercial finance provider operating in the United Kingdom. Our registered office is located at 49 Jamaica Street, Liverpool L1 0AH.

We provide commercial finance solutions to businesses across various sectors, connecting businesses with appropriate lending facilities to support their growth and operational needs.

Our Business Operations Include:

  • Commercial finance brokerage and arrangement
  • Assessment and processing of finance applications
  • Liaison with lenders and financial institutions
  • Client relationship management
  • Regulatory compliance and administration

We are authorised and regulated by the Financial Conduct Authority (FCA).

3. Our Supply Chains

Our supply chains are relatively limited compared to businesses in manufacturing or retail sectors. Our principal supplier relationships include:

3.1 Professional Services

  • Legal advisers and solicitors
  • Accountants and auditors
  • Compliance consultants
  • Business advisers

3.2 Technology and IT Services

  • IT support and managed services providers
  • Software and SaaS providers
  • Website hosting and maintenance
  • Telecommunications providers

3.3 Office and Business Services

  • Office supplies and equipment
  • Facilities management
  • Cleaning services
  • Utilities providers
  • Insurance providers

3.4 Financial Services Partners

  • Lenders and financial institutions
  • Credit reference agencies
  • Payment processors
  • Banking services

The majority of our suppliers are UK-based businesses operating in professional service sectors where the risk of modern slavery is generally considered to be lower. However, we recognise that modern slavery risks can exist in any sector and supply chain.

4. Our Policies on Modern Slavery

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. Our policies reflect our commitment to acting ethically and with integrity in all our business relationships.

4.1 Anti-Slavery and Human Trafficking Policy

We have developed an internal Anti-Slavery and Human Trafficking Policy which:

  • Sets out our zero-tolerance approach to modern slavery
  • Defines modern slavery and human trafficking
  • Outlines responsibilities of employees and management
  • Provides guidance on identifying potential indicators of modern slavery
  • Establishes reporting procedures for concerns

4.2 Code of Conduct

Our employee Code of Conduct makes clear to employees the standards expected in relation to:

  • Ethical business practices
  • Human rights and dignity
  • Fair treatment of all individuals
  • Reporting concerns and whistleblowing

4.3 Recruitment and Employment Practices

We are committed to fair employment practices, including:

  • Right to work checks for all employees
  • Transparent employment contracts
  • Fair wages above national minimum wage standards
  • No use of forced, bonded, or involuntary labour
  • Freedom of movement for all employees
  • No withholding of identity documents

4.4 Whistleblowing Policy

We encourage all employees, contractors, and suppliers to report any concerns related to modern slavery or human trafficking. Our whistleblowing procedures ensure:

  • Confidential reporting mechanisms
  • Protection from retaliation
  • Appropriate investigation of concerns
  • Action taken where issues are identified

5. Due Diligence Processes

We conduct due diligence on our suppliers and business partners to assess and manage the risk of modern slavery in our supply chains.

5.1 Supplier Assessment

When engaging new suppliers, we:

  • Evaluate the nature and location of their operations
  • Assess their modern slavery policies and practices
  • Include contractual provisions regarding modern slavery compliance
  • Prioritise suppliers who demonstrate ethical business practices

5.2 Ongoing Monitoring

We maintain ongoing oversight of our supplier relationships through:

  • Regular review of supplier performance
  • Periodic reassessment of modern slavery risks
  • Communication with suppliers about our expectations
  • Investigation of any concerns or red flags

5.3 Risk Assessment

We assess the risk of modern slavery in our supply chains by considering:

  • Geographic location of suppliers and their supply chains
  • Sector and industry risk factors
  • Nature of the work or services provided
  • Use of labour providers or subcontractors
  • Previous compliance history

6. Risk Areas and Mitigation

While our direct operations present relatively low risk, we have identified the following areas requiring particular attention:

6.1 Lower Risk Areas

  • Professional services (legal, accounting, compliance) – typically UK-based, regulated professions
  • Financial services partners – regulated entities with their own compliance obligations
  • Technology and software services – primarily established UK/EU providers

6.2 Areas Requiring Vigilance

  • Cleaning and facilities management: These sectors have historically shown higher risks of labour exploitation
  • IT hardware and equipment: Supply chains may extend to regions with higher modern slavery risks
  • Office supplies: Manufacturing supply chains may involve higher-risk jurisdictions

6.3 Mitigation Measures

For higher-risk areas, we:

  • Conduct enhanced due diligence on suppliers
  • Include specific modern slavery clauses in contracts
  • Request evidence of suppliers’ own modern slavery compliance
  • Consider modern slavery risks in procurement decisions
  • Maintain regular communication with suppliers

7. Training and Awareness

We are committed to ensuring our team understands modern slavery risks and how to identify and respond to potential issues.

7.1 Employee Training

We provide training to relevant employees covering:

  • What constitutes modern slavery and human trafficking
  • Potential indicators and warning signs
  • How to report concerns
  • The importance of ethical supply chains
  • Our policies and procedures

7.2 Management Responsibility

Our management team takes responsibility for:

  • Implementing this statement
  • Ensuring compliance with relevant policies
  • Overseeing supplier due diligence
  • Reviewing and addressing any reported concerns

8. Measuring Effectiveness

We measure the effectiveness of our efforts to prevent modern slavery through:

8.1 Key Performance Indicators

  • Number of suppliers assessed for modern slavery risks
  • Percentage of key suppliers with modern slavery policies in place
  • Number of employees trained on modern slavery awareness
  • Number of modern slavery concerns reported and investigated
  • Supplier contract compliance with modern slavery clauses

8.2 Regular Review

We regularly review:

  • Our modern slavery risks and controls
  • The effectiveness of our due diligence processes
  • Supplier compliance with our requirements
  • Employee awareness and training needs
  • Industry best practices and guidance

9. Reporting Concerns

We encourage anyone who has concerns about modern slavery in our business or supply chains to report them immediately.

Internal Reporting

Employees can report concerns to:

External Reporting

Concerns can also be reported externally to:

  • Modern Slavery Helpline: 08000 121 700
  • Crimestoppers: 0800 555 111
  • Police: 999 (in an emergency) or 101 (non-emergency)

All reports will be taken seriously and investigated appropriately.

10. Looking Forward

We are committed to continuous improvement in our approach to preventing modern slavery. In the coming year, we will:

  • Continue to review and enhance our supplier due diligence processes
  • Provide regular training to employees on modern slavery awareness
  • Engage with suppliers to promote awareness of modern slavery risks
  • Monitor developments in legislation and best practice
  • Review and update our policies and procedures as needed
  • Consider implementing supplier audits for higher-risk categories

11. Our Commitment

Liverpool Commercial Finance is committed to:

  • Operating our business ethically and with integrity
  • Respecting human rights in all our operations
  • Ensuring transparency in our supply chains
  • Working only with suppliers who share our values
  • Taking action to address any instances of modern slavery
  • Continuous improvement in our approach

We understand that eliminating modern slavery requires ongoing vigilance and effort, and we are committed to playing our part in addressing this serious issue.

12. Board Approval

This statement has been approved by the board of directors/senior management of Liverpool Commercial Finance and will be reviewed annually.

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending [Insert Date].

Signed:

[Director Name]
[Director Title]
Liverpool Commercial Finance

Date: [Insert Date]

13. Contact Information

For questions about this Modern Slavery Statement or to report concerns, please contact:

Liverpool Commercial Finance
49 Jamaica Street
Liverpool L1 0AH

Email: compliance@liverpoolcommercialfinance.co.uk
General Enquiries: admin@liverpoolcommercialfinance.co.uk

This statement will be reviewed and updated annually. The current version is available on our website at liverpoolcommercialfinance.co.uk