Modern Slavery Statement 2023
This statement is made pursuant to Section 54, Part 6 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.
Foundation for Credit Counselling (of 123 Albion Street, Leeds, LS2 8ER) trades as StepChange Debt Charity and StepChange Debt Charity Scotland.
A registered charity under nos.1016630 and SC046263; we are a limited company registered in England and Wales (company no: 2757055), who 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 our services and how each supplier relationship is managed, in order to keep our supply chain robust and ethical.
As the leading debt advice charity in the UK, we have around 1,200 colleagues (as at 31 December 2022) working in eight locations across England, Wales and Scotland. Our colleagues are largely directly employed and are generally not in any category that could be seen 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 key suppliers.
We are funded by voluntary donations from creditors and partners, and grants from public bodies, and are governed by an independent Board of Trustees chaired by John Griffith-Jones. The Trustees are collectively responsible for delivering the long-term success of the Charity, with the Executive team responsible for day-to-day management.
Our supply chain
The Charity’s supply chain network provides services which support the delivery of our day-to-day debt advice and debt management operations. A dedicated central Procurement team ensures a robust and ethical procurement process is followed to contract with new suppliers, and due diligence is carried out to confirm compliance with the Modern Slavery Act 2015.
Key supplier relationships are actively managed to ensure suppliers continue to adhere to the Modern Slavery Act 2015 for the duration of the relevant contract term.
The Charity has a zero-tolerance approach to slavery and human trafficking and all colleagues are expected to report any concerns immediately - these will be duly 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 Assurance Framework – this covers not only how we choose to procure a particular service from a supplier, but also how ongoing due diligence requirements are met and how supplier performance is reviewed.
- Risk assessment and 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 risk.
- Whistleblowing (‘Speak Up’) policy – we encourage colleagues to report any concerns without the fear of retaliation. Concerns can be raised through an independent third party, to the Director of Risk & Compliance, the Chief Executive Officer or the Chair of the Board of Trustees.
- 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 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 to take into account equal opportunities, recognised good practice and the needs of the Charity. Robust checks are completed to ensure colleagues are legally entitled to work in the UK and every colleague is issued with a contract. All colleagues are paid in excess of the Minimum Wage, and the Real Living Wage. No-one under the legal minimum age for admission to work is employed by the Charity. The charity does not enlist the help of volunteers in the operation of the charity.
- Training – all colleagues are required to complete annual e-learning modules encompassing both code of conduct (including whistleblowing procedures) and risk management.
The Charity is committed to acting ethically and with integrity in all its commercial relationships. We have a zero-tolerance policy towards slavery and human trafficking and expect all organisations within our supply chain to comply with our values. They are expected to meet the prescribed regulations and on-going monitoring will be carried out as part of the Supplier Management Process. We therefore do not believe that there are significant risk areas with a likely potential for slavery.
This statement was approved by the Board of Trustees on 21 February 2023.
Name: John Griffith-Jones (Chair of the Board)
Date: 21 February 2023