Modern Slavery Statement

Our public commitment to responsible business, ethical working practices and proportionate supply-chain oversight.

1. Purpose and commitment

Quorum Fleet Solutions Ltd, trading as Q-Finance ("Q-Finance", "we", "us" or "our"), is committed to conducting business responsibly, ethically and with integrity. We have zero tolerance for modern slavery, human trafficking, forced or compulsory labour, servitude, debt bondage, unlawful child labour or any other form of exploitation.

This policy explains how we seek to identify, assess and manage modern slavery risks within our own business and the supply chains and commercial relationships connected with our activities. It has been prepared with regard to the Modern Slavery Act 2015 and current Home Office transparency-in-supply-chains guidance.

Our approach is risk-based and proportionate. We do not claim that every link in every supply chain is risk-free; our commitment is to take reasonable steps to identify risks, act on concerns and improve our controls over time.

2. Our organisation and supply chain

Q-Finance is a UK financial services business operating principally within the motor finance sector. Our activities are predominantly office- and technology-based and involve consumers, motor dealers and introducers, lenders, regulated financial services businesses and third-party service providers.

Our direct supply chain is therefore different from the manufacturing, agricultural and labour-intensive sectors traditionally associated with higher modern slavery exposure. However, we recognise that exploitation can occur in any industry and may arise indirectly through subcontracting, recruitment, facilities services, technology hardware and international supply chains.

The types of organisations and services we may engage include:

• banks, lenders and other regulated financial services providers;
• motor dealers, appointed representatives, introducers and other distribution partners;
• software, IT, cyber-security, data, identity-verification and telecommunications providers;
• professional advisers, recruitment providers and other business support services;
• office, facilities, maintenance and cleaning providers; and
• equipment, hardware, print, marketing and promotional goods suppliers.

3. Policies and standards

Our modern slavery approach sits within our wider framework of responsible employment, financial crime prevention, compliance, whistleblowing, outsourcing and third-party oversight.

We do not knowingly engage in or support exploitative employment practices. In particular, we do not tolerate:

• forced, bonded or compulsory labour;
• human trafficking, servitude or unlawful child labour;
• the withholding of wages, passports or identity documents as a means of control;
• unlawful recruitment fees or coercive recruitment practices;
• threats, intimidation or retaliation against people who seek to leave employment or raise a genuine concern; or
• any equivalent practice that deprives a person of freedom or exploits vulnerability.

We expect our suppliers and commercial partners to operate lawfully and ethically and to take concerns about labour exploitation seriously.

4. Due diligence and ongoing oversight

We apply proportionate due diligence when establishing and maintaining material supplier and commercial relationships. The depth of review depends on the nature of the service, location, regulatory status, subcontracting arrangements, workforce profile and any reputational or modern slavery indicators identified.

Relevant checks may include:

• verification of the organisation, ownership and relevant regulatory status;
• Companies House, financial, reputational or adverse-media checks where appropriate;
• consideration of the location from which goods or services are supplied;
• review of subcontracting, outsourcing or recruitment arrangements where they create additional risk;
• requests for policies, assurances or further information where a risk is identified; and
• ongoing monitoring or enhanced review for higher-risk relationships.

Due diligence is not treated as a one-off exercise. If information comes to our attention that suggests exploitation or other serious unethical conduct, we will assess the concern and determine what further action is appropriate.

5. Risk assessment and management

We consider our directly employed, office-based UK workforce to have a comparatively low inherent modern slavery risk, while recognising that no organisation should assume the risk is zero. We focus attention on areas where the nature of the workforce, geography or supply chain may create greater exposure.

Area	Indicative risk	How we respond
Direct UK workforce	Lower	Recruitment controls, right-to-work checks, formal employment terms, payroll controls and accessible escalation routes.
Regulated / professional services	Lower to moderate	Counterparty verification, regulatory checks where relevant and proportionate ongoing oversight.
Recruitment, cleaning and facilities	Potentially higher	Greater attention to labour sourcing, intermediaries, employment practices and adverse indicators.
Hardware and promotional goods	Potentially higher	Consideration of international manufacturing and raw-material supply chains where material.
Overseas or complex supply chains	Potentially higher	Enhanced due diligence where geography, sector or subcontracting increases exposure.

6. Responding to concerns

Any credible concern relating to modern slavery or human trafficking will be taken seriously and considered promptly. Depending on the circumstances, we may seek further information, conduct enhanced due diligence, require remediation, increase monitoring, suspend or terminate a relationship and/or refer suspected criminal conduct to an appropriate authority.

When determining an appropriate response, we will consider the safety and welfare of any potentially affected person and seek to avoid action that could inadvertently increase the risk to them.

Employees are expected to raise concerns through their line manager, the Compliance function or the Managing Director. Customers, suppliers and other third parties may raise concerns using the contact details available on the Q-Finance website.

7. Measuring effectiveness

We monitor the effectiveness of our approach using proportionate management information. Indicators may include:

• completion of required modern slavery or relevant compliance awareness training;
• completion of appropriate due diligence for new material third-party relationships;
• the number of higher-risk relationships identified and subject to enhanced review;
• the number and nature of modern slavery concerns raised, investigated or remediated;
• any relationship suspended or terminated because of credible ethical or labour concerns; and
• completion of the annual policy and control review.

We do not regard a lack of reported incidents, on its own, as proof that controls are effective. We also consider whether people understand the warning signs, know how to escalate concerns and whether our due diligence produces meaningful action when risk is identified.

8. Training and awareness

Relevant employees receive awareness appropriate to their role. Training and guidance may cover the meaning and forms of modern slavery, common indicators, recruitment and supplier risks, vulnerable workers, escalation routes and the importance of avoiding actions that could place a suspected victim at greater risk.

Additional guidance may be provided to employees involved in recruitment, procurement, compliance, supplier management, dealer onboarding and oversight or management decision-making.

9. Governance and review

The Managing Director has ultimate oversight of this policy. Compliance supports its implementation, monitoring and periodic review. The policy will be reviewed at least annually and sooner where there is a material change in our business, supply chain, legal obligations or risk profile.

Where Quorum Fleet Solutions Ltd meets the statutory criteria under section 54 of the Modern Slavery Act 2015, we will prepare and publish the required annual modern slavery statement in accordance with the applicable legal requirements. We may also publish statements voluntarily where doing so supports transparency and good governance.

If anything here is unclear, contact us on 0191 380 4680 or email [email protected].