1. Purpose
This statement explains our commitment to better understanding our supply chains and collaborating with stakeholders who wish to improve transparency and address incidents of slavery or human trafficking. This applies not just to our own practices but also to the identification of opportunities in wider society where we might be able to make a difference.
2. Scope
This Policy is applicable to all business areas within Azzurro and its subsidiaries, including, Solaris Law Commercial and Solaris Law and overseas jurisdictions and should be read and understood by all members of staff.
This statement covers the business activities of Azzurro Associates (Azzurro) which are as follows:
- Azzurro Associates is regulated by the Financial Conduct Authority (FCA) and is an established debt purchaser across the credit cycle with solutions for performing debt pools through to aged and written off accounts.
- Solaris Law Commercial is regulated by the Solicitors Regulation Authority (SRA) and offers specialist business-to-business legal recoveries and dispute resolution service.
- Solaris Law is regulated by the FCA and the SRA and offers specialist consumer collections, legal recoveries and dispute resolution services.
- Next Finance is licenced by the Netherlands Authority for the Financial Markets and manages a closed portfolio of debts purchased in the Netherlands.
Azzurro does not engage in high-risk activities, nor does it have operations or supplier relationships in countries identified as having a high risk of modern slavery or human trafficking.
The scope of this statement also covers Azzurro’s supplier network which include a panel of Debt Collection Agencies and Law Firms who interact with customers on a daily basis.
It applies to all individuals working for Azzurro and its subsidiaries, at all levels of the business, including members, officers, directors, employees, consultants, homeworkers, part-time and fixed-term workers, casual and agency staff (collectively referred to as employees in this statement).
This statement is reviewed annually and does not form part of any employee’s contract of employment and we may amend it at any time.
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 ‘Transparency in Supply Chains’.
3. Policies in relation to slavery and human trafficking
Azzurro is committed to ensuring that its suppliers adhere to the highest standards of ethics. Serious violations will lead to the termination of the business relationship.
Our employee policies and procedures set out our requirements on such issues as disciplinary, grievance, equal opportunities, flexible working, harassment and bullying, home and mobile working, mental health and wellbeing, pandemics, recruitment best practice and time off for dependent care.
We expect all employees to conduct business with honesty and integrity and we have a zero-tolerance approach to bribery and corruption with policies and regular training undertaken on this and other such issues as anti-money laundering, gifts and hospitality and counter terrorist financing.
Our whistleblowing policy sets out the process for reporting any concerns about wrongdoing or breaches of policies including forced or compulsory labour or human trafficking. If anyone has any concerns about raising a matter internally.
We expect our suppliers to share our commitments and approach and by collaborative working we believe we can jointly have a positive impact on society.
HR acts as our lead anti-slavery champion responsible for guiding the business on best practice and raising staff awareness and is responsible for implementing procedures. The Board has ultimate responsibility for directing and reviewing the Modern Slavery programme and the annual modern slavery statement.
4. Due diligence processes in relation to slavery and human trafficking within our business
Our employment strategy is based on attracting, developing and retaining the best talent by reinforcing our values and providing a stimulating and rewarding work environment. We recognise everyone is unique and has special contributions to make in delivering the business strategy. Employee engagement is at the heart of our approach and we want to inspire and empower our people to use their talents positively in our communities, whether that be locally, regionally, nationally or ultimately at a global level.
Our recruitment and employment procedures include appropriate pre-employment screening of all staff to determine the right to work in the UK where all our offices are based. Candidate sourcing is predominantly managed directly by the inhouse HR team. We have greatly reduced our use of recruitment agencies, but when they are required all recruitment suppliers are based in the UK and agree to our terms and conditions.
To the best of our knowledge there are no suppliers using a third party within the process and we deal directly with each supplier who is tasked with delivering the relevant service.
5. Due diligence processes in relation to slavery and human trafficking within our business supply chain
As Azzurro have office locations solely in the UK it is considered that the level of risk of modern slavery or trafficking within the business is low but there is no room for complacency.
Effectiveness in ensuring that slavery and human trafficking is not taking place in its business and supply chains and key performance indicator measures
Azzurro has not identified any internal business procedures that could make demands of suppliers or contractors that might lead them to violate human rights and we will continue to keep this under review.
Azzurro has not been informed of any incidents of slavery or trafficking with its own employees or those of its suppliers but it will investigate any allegations should they arise and take appropriate action accordingly.
Through our supplier onboarding process, we undertake defined levels of due diligence depending on the size and risk of the supplier and the goods and services they are providing.
6. Staff training and capacity building about slavery and human trafficking
E-learning training is made available to nominated individuals within each business overseeing compliance with our slavery and human trafficking requirements. The e-learning training covers four modules providing an introduction to modern slavery, what are the signs, action to take and an assessment of understanding.
In conclusion, we are committed to better understanding our supply chains and collaborating with stakeholders who wish to improve transparency and address incidents of slavery or human trafficking. This applies not just to our own practices but also to the identification of opportunities in wider society where we might be able to make a difference. We are particularly keen to hear from like-minded organisations so that we can explore collaborative opportunities.
7. Conclusion
In conclusion, we are committed to better understanding our supply chains and collaborating with stakeholders who wish to improve transparency and address incidents of slavery or human trafficking. This applies not just to our own practices but also to the identification of opportunities in wider society where we might be able to make a difference. We are particularly keen to hear from like-minded organisations so that we can explore collaborative opportunities.
8. Governance
This policy is owned by HR, approved by Excom, with oversight from Compliance.
