Modern Slavery and Human Trafficking Transparency Statement 2023
Introduction
At Stenn, we are committed to playing our part in helping prevent any incident of modern slavery in our organisation and have a zero-tolerance approach to modern slavery.
Stenn is committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere within our business or in any of our supply chains.
This statement is issued by Stenn in accordance with section 54(1) of the UK Modern Slavery Act 2015. Our statement sets out the steps we take and have taken to assess and address the risks of modern slavery (including forced labour and human trafficking) in our operations and supply chains.
We also expect the same high standards from all of our contractors, suppliers, and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory, or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their suppliers to the same high standards.
Our Organisation
Stenn is a London-based FinTech that delivers rapid finance to SMEs in global supply chains.
Policies
Stenn, at all times, is committed to conducting our business in compliance with all legislation and regulations, which are relevant to our business within the countries that we operate. In keeping with our commitment to act with integrity in all our business dealings, our existing policies are relevant to ensuring that there is no slavery or human trafficking in any part of our business or our supply chains.
We expect our suppliers, partners, and customers to also meet these high standards. Stenn has reviewed and kept up-to-date internal policies, instructions, and governance demonstrating our commitment, requiring employees to raise concerns about any identified or suspected non-compliance, and confirming that employees will not suffer any detriment for raising such concerns. These internal policies, instructions, and governance include, but are not limited to, the following:
● Anti-money laundering and counter-terrorist financing;
● Code of conduct and ethics;
● Whistleblowing.
Due Diligence and Risk Management
Before entering into a relationship with a new supplier, partner or customer, we conduct due diligence activities to assess the risks of partnering with that supplier, partner and customer and to provide assurance that the supplier, partner and customer meet expectations regarding adequate controls. As part of these due diligence exercises, we conduct a series of checks that take account of risks including product type and country of origin risk, and financial crime indicators.
Terms & Conditions:
Our contracts with our suppliers and customers contain specific terms and conditions which require them to comply with all applicable laws and regulations in their provision of goods or services and to conduct their business in accordance with our standards and expectations. We reserve the right to terminate our contracts with suppliers and our customers for non-compliance with such laws, regulations, and standards.
Ongoing Monitoring:
We conduct ongoing monitoring of our suppliers and our customers to ensure that they are compliant with their contractual commitments and are delivering products or services by our standards. Suppliers and customers that present heightened risks maybe subject to additional audits or reviews.
Performance
Stenn is committed to adherence to the risk management approach and due diligence processes noted in this statement when working with suppliers and customers. All new employees are required to complete a mandatory compliance training module as part of their onboarding process. This training data will be monitored and reported to the People team with the targeted completion of 100% of employees within 90 days of starting employment at Stenn.
As part of our commitment to ongoing excellence and compliance, the intention is to ensure that as a component of our regular compliance training cadence, all employees will be required to complete a regular refresher course every year to ensure knowledge and understanding are up to date.
This statement was approved by the Stenn Board of Directors on 5 October 2023. It will be updated annually within six months of each financial year end.