Our Company
TMG Partners Limited is a financial services business with its
registered office within the UK, which offers a range of financial
products through its subsidiary companies, including credit score
services, secured and unsecured personal loans, credit card and
mortgages as a broker, personal accounts and debt advice and insolvency
services. The subsidiaries include:
- Financial Wellness Group Limited
- Freeman Jones Limited
- Freeman Jones (UK) Limited
- Gregory Pennington Limited
- Benesse Advice Limited
- MoneyAppi Ltd
- Ideal Finance Limited
- Intelligent Lending Limited (trading as Ocean and Ocean Finance)
- CredAbility Limited
- Think Insure Limited
- Think Money Limited
- TMG Partners Limited
This statement is on behalf of TMG Partners Limited and its
subsidiaries.
Our Policies
We are committed to ensuring that there is no modern slavery or human
trafficking in our supply chain or in any part of our business. Our
policies, specifically: Anti-slavery and Human Trafficking Policy,
Whistleblowing Policy, Conflicts of Interest Policy and Supplier
Management Framework reflect the Group’s values and in turn our
commitment to act ethically and with integrity in our business
relationships.
Our Supply Chains
As we are engaged in the provision of financial services our supply
chain is relatively straightforward. We remain focused to ensure that
all our goods and services are supplied from compliant providers to run
our business effectively and ethically.
Our Due Diligence Practices
As part of our initiative to identify and mitigate risk we perform due
diligence on all new suppliers aimed at assessing their business across
a number of areas including information security, legal and regulatory
compliance and financial conduct. This due diligence exercise includes
specific questioning on modern slavery and human trafficking.
In addition to the due diligence performed on new suppliers, existing
suppliers are required to complete a self-assessment questionnaire
annually which further addresses compliance with the requirements of the
Modern Slavery Act 2015 (Act).
Supplier Adherence to our Values
We have zero tolerance to slavery and human trafficking. To ensure all
those in our supply chain and contractors continue to comply with our
values we have in place a supply chain compliance programme which is
monitored by our compliance team, and involves input from the following
departments: Legal, Compliance, Audit and Procurement.
TMG only trades with suppliers who comply with these policies.
Risk Assessment
Due to the nature of the services we provide, we consider the inherent
risk of modern slavery and human trafficking occurring in our business
to be low. However, we take our responsibility to identify and
effectively respond to any incidents of modern slavery and human
trafficking very seriously and will continue to review our policies and
procedures and make enhancements where we deem necessary.
Key Performance Indicators
We use the following key performance indicators (KPIs) to measure how
effective we have been to ensure that slavey and human trafficking is
not taking place in any part of our business or supply chains:
-
Regular due diligence – the number of supplier reviews, subject to a
risk based approach
-
Training and education – the number of individuals that training is
provided to
Training
We ensure that all of our employees and our supplier chains have a high
level of understanding of the risks of modern slavery and human
trafficking, and are made aware of the provisions, requirements and
importance of the Act.
All training of the Act and the wider issues of slavery and human
trafficking is completed through our online portal.
Further Actions
Following a review of the effectiveness of the steps we have taken so
far to ensure that here is no slavery or human trafficking in our supply
chains, we intend to take the following further steps to combat slavery
and human trafficking:
-
Continue to strengthen our reviews of our key suppliers and partners
to include compliance with the Act
-
Enhance training and policies to clearly articulate the minimum
standards of the Act, and to implement and embed across the Group and
its subsidiaries.
This statement is made pursuant to section 54(1) of the Modern Slavery
Act 2015 and constitutes our Group’s slavery and human trafficking
statement for the financial year ending 31st January 2024.
Stephen Stylianou, CEO
August 2024