CC365 is a leading UK online car and home finance broker. The business is organised into Three divisions: CarCredit365, HomeCredit365, and, FinanceAnyMotor
Due Diligence Process for Slavery and Human Trafficking
CC365 employees are based in the UK. Employee relations are managed consistently across the business by the Human Resources department. All relevant colleagues are paid at least the UK National Minimum Wage.
Services procured through third parties are in the process of being grouped into tiers, based on value, importance and risks to CC365. This will allow us to identify which of our service providers we should focus the most attention on.
We will be writing to suppliers seeking assurance that the principles of the Act are being followed/adopted, though clearly expecting a more complete and robust attestation from those few suppliers who directly fall under the Act. Where no assurance is forthcoming, we will engage with those parties at contract review to ascertain whether there is sufficient concern to replace them.
Additionally, we are in the process of supplementing this policy with a Supplier Code of Conduct which will reflect our existing commitment to operate ethically and with integrity in all our business relationships. The implementation and enforcement of effective systems and controls within the organisation and our supply chains will safeguard against slavery and human trafficking.
Risks to CC365 associated with the Act are managed in accordance with the business’s Risk Management Framework. Additionally the business operates a Whistleblowing Policy and actively encourages the reporting and exposure of unethical behaviour.
Responsibility for this Policy
The Board of CC365 has overall responsibility for ensuring this policy complies with our legal and ethical obligations. CC365 encourages all of its employees, consultants, workers and contractors to report any concerns they have about slavery and/or human trafficking affecting the business, even if they turn out to be mistaken.
Steps for the Prevention of Modern Slavery
All suppliers, contractors and other business partners will also be made aware of CC365’s zero tolerance approach to modern slavery and will be expected to adopt the same approach.
The following internal policies are also in place, or are being developed, to monitor and reduce the risk of modern slavery and human trafficking in our business:
Third Party Due Diligence Policy, Whistleblowing Policy, Financial Crime Policy, Health and Safety Policy.
We regularly consider the level of risk of slavery and human trafficking pose to CC365, its suppliers, contractors and business partners and given the nature of the companies in our supply chain, we consider this risk is very low.