Voluntary statement on slavery and human trafficking
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as 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.
The Credit Services Association is making a voluntary statement on modern slavery and human trafficking relating to section 54 of the Modern Slavery Act 2015.
We are a not for profit trade association acting for members in the debt collection, debt sale and purchase industry. With over 300 Members and between them representing about 90% of the industry, CSA Members either own or manage around £67bn of debt, equating to around 52 million accounts. As the voice of the collections industry, our vision is to build confidence in debt collection by making the entire process clear, easy to understand and less stressful for all those involved.
Given our size as an organisation, we are not legally required to make a modern slavery statement. However, we are making this voluntary statement to show our commitment to ethical trading principles, that we oppose slavery and human trafficking in all its forms and are taking steps to ensure that there is no slavery or human trafficking in our business or in our supply chain.
Policies and organisation
The CSA operate an Anti-slavery and Human Trafficking Policy which reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chain.
Our Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The Director of Finance and Operations has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Our people at all levels are encouraged to report concerns about any issue or suspicion of modern slavery in any parts of our business or supply chain.
Due diligence and risk assessment
To help identify and monitor the risk of slavery and human trafficking in our supply chain we commit that we will vet suppliers and sub-contractors to ensure that they use ethical labour practices.
We will only employ agency workers through reputable employment agencies that adhere to our anti-slavery and human trafficking policy (or equivalent policies). As part of our procurement policy we will apply certain due diligence criteria to confirm that suppliers or potential suppliers and subcontractors comply with our own ethical standards.
In accordance with the guidelines set out by the Home Office we have analysed the categories of our supply chain below:
- PRINCIPAL SUPPLIERS - our largest cost relates to the employment of our own people and the use of self-employed tutors in the case of our Learning and Development activities. In this context we are already fully committed to paying people in line with living wage guidelines. Our arrangements with tutors do not permit any sub-contracting and while we may subcontract to providers of professional qualifications, regulations prevent any second level subcontracting.
- The balance of costs are associated with services delivered in our offices and at third party venues (for training, conferences and seminars) for which we use well-known and reputable companies and we will now check their statements and policies in relation to modern slavery as far as we are able as part of due diligence processes.
- PRODUCTS OR RAW MATERIALS SUPPLIERS - as a trade association we do not directly process raw materials but do receive small amount of stationery and promotional products which are generally sourced from suppliers we know well. As far as is practical we will also ascertain their ethical standards in relation to slavery and human trafficking.
- IT SERVICES - these are provided through a self-employed contractor who is only allowed to subcontract his services or provide a replacement with our permission.
- CONTRACT CLEANING SERVICES - these are provided by a large third-party company who are corporate members of their industry trade body, the British Institute of Cleaning Science, which promotes best practice with regards people employed in the industry.
- MANUFACTURING SERVICES - as a trade association we do not directly engage in manufacturing.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chain and our business, we provide guidance to our staff, particularly in so far as they are involved in procurement. Our Anti-slavery and Human Trafficking policy also encourages our people to use our Whistleblowing Policy if they have any suspicion or concern of modern slavery violations without fear of any detrimental treatment.
On an annual basis we will review the effectiveness of the steps we have taken during the year to ensure that there is no slavery or human trafficking in our supply chain and to identify any additional steps we intend to take to combat slavery and human trafficking.
This voluntary slavery and human trafficking statement is made in connection with section 54(1) of the Modern Slavery Act 2015, for the financial year ending 30 June 2019. It was approved by the board on 11th December 2019.
Peter Wallwork (Chief Executive Officer)
CREDIT SERVICES ASSOCIATION
Date: 11th Decemeber 2019