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Statement on Modern Slavery and Human Trafficking 2021

The Equivo slavery and human trafficking statement is made pursuant to Section 54 of the Modern Slavery Act 2015 ‘Transparency in Supply Chains’. The statement is updated annually.

Equivo structure, business and supply chain

Equivo was launched on 1 June 2021 as an innovative full-service recoveries business that delivers tech-enabled services to the highest standards across all stages of the debt and recoveries lifecycle.

Equivo is a trading name of Equivo Limited.

Equivo Limited is a limited liability company registered in England and Wales number 12058753. Equivo Limited’s registered office is Abbots House, Abbey Street, Reading, RG1 3BD. The addresses and contact information for each of our trading addresses can be found under the "Contact us" section of our website.

Equivo Limited is authorised and regulated by the Financial Conduct Authority (FCA). Firm Reference Number is FRN 845356. Details can be found on the Financial Services Register at register.fca.org.uk. We offer consumer credit and mortgage debt recoveries services.

Equivo Limited is also authorised and regulated by the Solicitors Regulation Authority (SRA), our SRA number is 811299. Our professional rules can be accessed, in English, from the Solicitors Regulation Authority website at www.sra.org.uk/solicitors/standards-regulations.

Equivo Limited has three key divisions; Collections & Field, Legal Services and Enforcement covering all disciplines within the recoveries lifecycle. Equivo Limited is authorised and regulated by the Financial Conduct Authority, the Solicitors Regulation Authority and authorised by the Ministry of Justice, coming together to enable unique in-house capabilities and expertise at national scale across four regional offices and supported by a nationwide field team.

We offer consumer credit and mortgage recoveries services and our clients include leading financial institutions.

Equivo’s Mission, is ‘to deliver complete and combined recoveries services by empowering experienced experts with leading technology. We are dependable and effective, setting the highest standard to ensure a fair customer-focused outcome that our clients are proud to put their name to’ with a vision of ‘setting the standard for recoveries resolution by achieving what is right and fair while treating everyone with respect and sensitivity’

We operate three business units:

  • Collections – including vehicle repossessions, field activity from County Court to FCA-regulated field activity
  • Consumer Litigation
  • Enforcement Activity

Business support teams include: Finance, HR, Estates management, Information Technology, Compliance and Risk.

Policies in relation to slavery and human trafficking

Our responsible business policies and statements in the public domain most relevant to this agenda will be:

  • Corporate responsibility policy
  • Supplier code of conduct
  • Environment policy
  • Health and safety policy
  • Modern slavery act policy
  • Privacy notice
  • Statement about the anti-facilitation of tax evasion
  • Whistleblowing policy

Our employee policies and procedures set out our requirements on such issues as disciplinary, grievance, equal opportunities, flexible working, harassment and bullying, home and mobile working, mental health and wellbeing, pandemics, recruitment best practice and time off for dependent care.

We expect all employees to conduct business with honesty and integrity and we have a zero-tolerance approach to bribery and corruption with policies and regular training undertaken on this and other such issues as anti-money laundering, gifts and hospitality and counter terrorist financing.

Our whistleblowing policy sets out the process for reporting any concerns about wrongdoing or breaches of policies including forced or compulsory labour or human trafficking. If anyone has any concerns about raising a matter internally.

We have a policy and guidance on compliance with the modern slavery act duty to notify regulations.

We expect our suppliers to share our commitments and approach and by collaborative working we believe we can jointly have a positive impact on society. Our priority suppliers will be invited to sign up to our supplier code of conduct covering laws and regulations, under age and forced labour, freedom of association, discrimination, wages and benefits, working hours, healthy and safe working conditions, environment, business integrity, discipline and grievances.

HR acts as our lead anti-slavery champion responsible for guiding the business on best practice and raising staff awareness and is responsible for implementing procedures. The Board has ultimate responsibility for directing and reviewing the Modern Slavery programme and the annual modern slavery statement.

Due diligence processes in relation to slavery and human trafficking in Equivo business

Our employment strategy is based on attracting, developing and retaining the best talent by reinforcing our values and providing a stimulating and rewarding work environment. We recognise everyone is unique and has special contributions to make in delivering the Equivo strategy. Employee engagement is at the heart of our approach and we want to inspire and empower our people to use their talents positively in our communities, whether that be locally, regionally, nationally or ultimately at a global level.

Our recruitment and employment procedures include appropriate pre-employment screening of all staff to determine the right to work in the UK where all our offices are based. Candidate sourcing is predominantly managed directly by the inhouse talent acquisition team. Over the last three years we have greatly reduced our use of recruitment agencies, but when they are required all recruitment suppliers are based in the UK and agree to our terms and conditions.

To the best of our knowledge there are no suppliers using a third party within the process and we deal directly with each supplier who is tasked with delivering the relevant service.

Due diligence processes in relation to slavery and human trafficking in Equivo’ supply chains

Through our supplier onboarding process, we undertake defined levels of due diligence depending on the size and risk of the supplier and the goods and services they are providing. Suppliers are also asked to sign the Equivo supplier code of conduct which sets out the behaviours we expect from our supply chain.

Within our estates management function Fisco UK Ltd works with Equivo directly managing and taking ownership of all second tier Facility Management contract services – cleaning consumables, couriers, landscaping, waste and recycling and all building services contracts. All new suppliers are vetted, and an annual compliance review is undertaken to include pre-employment screening, training, health, safety, environmental and modern slavery compliance.

It is standard practice for estates management to approach all the tier one and two estates management suppliers (excludes tier three sub-contractors not contracted by Equivo). Existing suppliers who signed the code of conduct are sent the questionnaire on an annual basis. For new suppliers we send out the questionnaire and code of conduct. We pay particular attention to those where unskilled labour is required i.e. cleaning, window cleaners, caterers etc. and we focus on the direct supply of products i.e. stationery and specialist branded products.

Parts of the business and supply chain where there is a risk of slavery and human trafficking taking place and steps taken to assess and manage that risk

As a professional services firm with office locations solely in the UK it is considered that the level of risk of modern slavery or trafficking within the business is low but there is no room for complacency.

Effectiveness in ensuring that slavery and human trafficking is not taking place in its business and supply chains and key performance indicator measures

Equivo is unable to determine if its approach is effective but is committed to continued work in this area.

Divisions and directorates have not identified any internal business procedures that could make demands of suppliers or contractors that might lead them to violate human rights and we will continue to keep this under review.

Equivo has not been informed of any incidents of slavery or trafficking with its own employees or those of it’s suppliers but Equivo will investigate any allegations should they arise and take appropriate action accordingly.

Staff training and capacity building about slavery and human trafficking

E-learning training is made available to nominated individuals within each division and business directorate overseeing compliance with our slavery and human trafficking requirements. The e-learning training covers four modules providing an introduction to modern slavery, what are the signs, action to take and an assessment of understanding.

In conclusion

In conclusion, Equivo is committed to better understanding its supply chains and collaborating with stakeholders who wish to improve transparency and address incidents of slavery or human trafficking. This applies not just to our own practices but also to the identification of opportunities in wider society where we might be able to make a difference. We are particularly keen to hear from like-minded organisations so that we can explore collaborative opportunities.

John Ingram
CEO
Equivo Limited

Date: 01 June 2021