Statement for the Financial Year 2016
This statement is made on behalf of Pepper (UK) Limited (the "Company") pursuant to section 54(1) of the Modern Slavery Act 2015.
The Company is incorporated in England and Wales with registered number 06548489. The Company’s registered office is at Harman House, 1 George Street, Uxbridge, Middlesex UB8 1QQ.
The Company originates residential mortgage loans and provides loan administration services as to loan assets secured by residential and commercial real estate located in the United Kingdom; and is part of the Pepper Group of companies (the "Pepper Group"); the ultimate parent of which, Pepper Group Limited, is listed on the Australian Stock Exchange.
The Pepper Group also operates various loan administration businesses, financial advisory and service businesses, and residential mortgage and consumer lending businesses in Australia, New Zealand, Ireland, Spain, South Korea, Hong Kong, and China.
The Company’s success depends not only on our technical ability, but also on our employees and wider workforce acting ethically. We are committed to complying with the applicable financial regulations and conduct rules that are prevalent in our industry, and also to creating a fair and transparent working environment within our business. This is demonstrated by our ‘Culture and Ethics Policy’, our ‘Whistleblowing Policy’, and the ‘Values’ set out in our Employee Handbook.
We expect the same of our material suppliers, and focus on developing relationships with these suppliers based on transparency. Although our material suppliers operate independently and in different industries, we recognise that their actions can impact our reputation. As such, we strive through our procurement diligence processes and third party supplier policies to select suppliers that share our values, and demonstrate a commitment to the highest professional standards and ethical conduct in their business dealings. Our Chief Operating Officer oversees our procurement process.
The nature of the Company’s business is such that our material supply chain consists primarily of professional services suppliers: such as solicitors, administrators, surveyors, storage facilities, office supplies and technology providers, substantially all of which are based in or operating from the United Kingdom. Consequently, we consider our supply chain to be low risk with regards to such relationships and ‘modern slavery’ and do not consider any further action to be necessary as an immediate next step to mitigate the risk of "modern slavery" in the supply chain.
We have not identified any areas requiring immediate action with regard to such relationships beyond our regular procurement diligence processes and our internal third party supplier policies.
We are, however, committed to taking all appropriate steps to mitigate the risk of slavery or human trafficking taking place in our supply chain. We regularly review our procurement and supply chain management procedures with a view to further reinforcing this commitment.