MAB Group Modern Slavery Statement 2022
This statement sets out the actions that Mortgage Advice Bureau (Holdings) plc (MAB Group) has undertaken to review the potential modern slavery risks that it might face, and to manage its processes that are aimed at ensuring that there is no slavery or human trafficking in its business or supply chains.
This statement relates to actions and activities during the financial year 1 January to 31 December 2022.
As part of the Financial Services sector, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.
Organisational structure and supply chains
MAB Group is one of the leading mortgage and protection specialists in the UK, offering expert mortgage and protection advice to consumers throughout the UK from a network of over 2,000 advisers. It also has an established operating business in Australia, via a joint venture.
Its main operating entity, Mortgage Advice Bureau Limited, has over 200 employees who are committed to supporting the day-to-day operation of the business of MAB Group, including overseeing the activities of the subsidiary entities.
The nature of MAB Group’s supply chain reflects the fact that it is primarily a recipient of services, rather than goods and materials. Essentially, it relies on a mix of general business suppliers (ranging from facilities management support to technology solutions), as well as financial services providers, such as mortgage providers and insurance providers. The relationships with many of these key suppliers and outsourcers are well-established, with appropriate governance and oversight procedures in place.
Process and Risk Assessments
MAB Group has implemented key processes to assess whether or not particular activities present material risks in relation to slavery or human trafficking. Specifically:
- It holds a Risk Register of all operations, and regularly reviews this in the context of supply chain and business operations.
- There are no high-risk activities identified in relation to modern slavery or human trafficking.
As set out below, a series of policies have been established and reviewed jointly by the Finance, Operations, and the Risk & Compliance teams. These are designed to set out the appropriate steps for assessing business activity and supply chain exposure and to enable risks assessments to be appropriately undertaken, with any known, or suspected, instances of slavery or human trafficking being fully investigated and reported.
MAB Group operates the following policies that describe its approach to the identification of modern slavery and human trafficking risks and the preventative steps to be taken in its operations:
- Whistleblowing policy– all employees and stakeholders are encouraged to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for individuals to make disclosures, without fear of retaliation. All persons affected have access to Protect (previously known as ‘Public Concern at Work’) (an independent whistleblowing charity) via their helpline.
- Employee Handbook- The organisation's employee handbook, including its ‘Behaviours Framework’, clearly sets out to employees the actions and behaviour expected of them. The organisation strives to maintain the highest standards of conduct and ethical behaviour in its operations, including managing its supply chain.
- Supplier code of conduct- The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of the organisation's supplier code of conduct will lead to the termination of the business relationship.
- Recruitment/Agency workers policy- The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency before accepting workers (although in general it does not use agency staff due to the nature of our regulated business). This is done via a ‘Preferred Supplier List’ (PSL) and the use of questionnaires with a full employee verification process to ensure that risks of slavery and human trafficking are addressed in relation to agency workers and all new hires.
Procurement and Due diligence
Over the last 12 months, MAB Group has reviewed and enhanced its procurement policies and procedures to better document and manage its relationships within its supply chain. In particular, it has implemented a new software solution that is designed to capture the key details of any supplier, and track their performance.
Naturally, the starting point for such relationship management and record keeping is the due diligence undertaken when considering taking on new suppliers, which includes:
- Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
- Evaluating the modern slavery and human trafficking risks of each new supplier;
- Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
- Conducting supplier audits or assessments through the organisation's own employees or third-party auditor, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
- Creating an annual risk profile for each supplier;
- Taking steps to improve substandard suppliers' practices, including providing advice to suppliers, sometimes through a third-party auditor, and requiring them to implement action plans;
- Participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular;
- Asking suppliers to confirm their compliance with our standards and requirements in order to provide products or services to our business; and
- Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.
MAB Group continues to review its key performance indicators (KPIs) in light of the requirements of the Modern Slavery Act 2015. As a result, it:
- Ensures that all employees are aware of the Modern Slavery Act 2015, and what it means at MAB;
- Operates a system for supply chain verification, whereby the organisation evaluates potential suppliers before they enter the supply chain; and
- Reviews its existing supply chains, whereby the organisation evaluates all existing suppliers.
To better understand and respond to potential slavery and human trafficking risks our employees are given awareness training, and suppliers are also made aware of our expectations.
Specifically, all employees within the organisation are required to complete training on modern slavery as a module within the organisation's wider Ethics training programme.
The organisation's modern slavery training covers;
- Purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below the national minimum wage, or the provision of products by an unrealistic deadline;
- How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
- How to identify the signs of slavery and human trafficking;
- What initial steps should be taken if slavery or human trafficking is suspected;
- How to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
- What external help is available, for example through the Modern Slavery Helpline, Gang masters and Labour Abuse Authority and "Stronger together" initiative;
- What messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
- What steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation's supply chains.
This statement has been approved by MAB Group’s board of directors and non-executive directors on 9 March 2023.
Peter Brodnicki, CEO on behalf of Mortgage Advice Bureau (Holdings) plc and its subsidiaries.