Foundation for Credit Counselling (of 123 Albion Street, Leeds, LS2 8ER) trades as StepChange Debt Charity and StepChange Debt Charity Scotland.
A registered charity in England and Wales under no. 1016630 and in Scotland under no.
SC046263, we are a limited company registered in England and Wales (company no: 2757055), which is authorised and regulated by the Financial Conduct Authority. StepChange is the parent company of:
- Consumer Credit Counselling Service (Equity Release) Limited trading as StepChange Financial Solutions (company no. 06741879); and
- Consumer Credit Counselling Service Voluntary Arrangements Limited trading as StepChange Voluntary Arrangements (company no. 05659160).
We recognise the importance of combating slavery and human trafficking and are
committed to reviewing on an ongoing basis the way in which we obtain goods and
services and how each supplier relationship is managed, in order to keep our supply
chain ethical.
As the leading debt advice charity in the UK, we have 1,040 colleagues (as of 1 January
2026) working in seven locations across England, Wales and Scotland. The majority of
colleagues are directly employed and are generally not in a category that could be
perceived as vulnerable to modern slavery. Therefore, our key focus is to ensure that we
have adequate policies and due diligence procedures in place for our supply chain.
Our supply chain network provides goods and services which support the delivery of our
day-to-day debt advice and debt management operations. Via a centralised
Procurement team, the Charity has implemented its Procurement and Supplier
Management Policy together with a set of standards and procedures to ensure such
modern slavery practices do not take place within the business of any organisation that
supplies goods or services to us. The Charity has undergone an internal audit of the
Policy and taken steps to mitigate any identified risks or exposure.
Key supplier relationships and contracts are actively managed to ensure suppliers
continue to adhere to the Modern Slavery Act 2015 for the duration of the relevant
contract term. This includes onboarding due diligence, supplier reviews and supplier
adherence to our values.
The Charity has a zero-tolerance approach to known issues pertaining to slavery and
human trafficking; as such all colleagues are expected to report any concerns
immediately - these will be fully investigated with action taken where required.
A number of internal policies and procedures are also embedded across the Charity and
are regularly reviewed. These include:
- Procurement and Supplier Management Policy and framework – This covers the full
procurement process including ethical procurement and the Modern Slavery Act 2015.
- Risk Management – we have a robust risk management framework embedded across
the Charity that ensures that risks are appropriately identified, assessed, and managed
in line with the Charity’s agreed risk appetite. This includes supply chain risks, which
are mitigated through proportionate and risk-based due diligence. Our due diligence
approach is tiered according to the criticality and strategic importance of each
supplier, ensuring that those with the greatest potential impact and exposure are
subject to enhanced scrutiny and ongoing monitoring.
- Whistleblowing (‘Speak Up’) Policy – we encourage colleagues to report any concerns
without the fear of retaliation. Concerns are raised through an independent third party,
which provides the option for the whistleblower to have anonymity if desired.
- Employee Code of Conduct – this sets out the behaviours we expect from colleagues
when representing the Charity during their daily activities. As such we expect them to
remain vigilant, to report concerns and to act with integrity and in an ethical manner.
- Recruitment Policy – all colleagues and Trustees are recruited through a selection
process that is carried out fairly and consistently considering recognised good
equality, diversity and inclusion practices and the needs of the Charity. All colleagues
are paid at least the statutory National Minimum Wage and the higher, voluntary Real
Living Wage. In addition, the Charity does not enlist the help of volunteers in the
operation of the Charity.
- Safeguarding Policy – the Charity’s safeguarding policy recognises the risk of modern
slavery or human trafficking and provides a mechanism for reporting such concerns.
In order to monitor and reduce the risk of slavery and human trafficking occurring within
our supply chains, we have embedded due diligence procedures in respect of both our
business-to-business suppliers and our HR and recruitment activities. These include
supplier questionnaires, risk assessments, contractual commitments, and the right to
conduct audits.
Our procedures are designed to:
- Establish and assess areas of potential risk in the Charity and supply chains
including the monitoring of potential risk areas.
- Reduce the risk of slavery and human trafficking occurring within the Charity and
supply chains.
- Provide adequate protection for whistle-blowers.
In assessing the effectiveness of managing Modern Slavery, the Charity considers the
following:
- Code of Conduct training completion rate: 98.79% (dated 7 January 2026)
- Number of instances of modern slavery reported within the Charity or our supply
chain: Zero
We invest in educating our staff to recognise the risks of modern slavery and human
trafficking in our business and supply chains. All colleagues are required to complete elearning modules encompassing both Code of Conduct and Risk Management, which
include information about what we mean by ‘modern slavery’, how to identify it and how
to report it, and also our whistleblowing procedures.
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets
out the steps the Charity has taken to ensure that slavery, forced labour and human
trafficking are not taking place in our supply chain or in any part of our organisation.
This statement was approved by the Board of Trustees on 26 February 2026