This statement has been published in accordance with Section 54 of the Modern Slavery Act 2015. It sets out the steps taken by Commercial and Northern Ltd (trading as B-North) to prevent modern slavery and human trafficking in its business and supply chains.
Commercial and Northern Ltd has a zero tolerance approach to modern slavery and human trafficking of any kind and we expect all the suppliers we work with to hold common values with us.
The Commercial and Northern Ltd’s Board of Directors has overall responsibility for ensuring our policies comply with our legal and ethical obligations, including those concerned with Modern Slavery & Human Trafficking. Additionally, the Board has responsibility for ensuring that all our staff comply with such policies and that turning a ‘blind eye’ to such practices is unacceptable.
Our Supply Chain
We aim to have mutually advantageous relationships with all our suppliers and actively seek suppliers that share the same values as us. Additionally, as an organisation building a financial services business, we are not in an industry with a high risk of modern day slavery or human trafficking.
Some of our suppliers do operate supply chains that are global in their nature and have a higher risk of not meeting these aims, such as IT and electronics manufacture, including the disposal, dismantling and recycling of equipment. As part of the process of engaging with a supplier, we seek to ensure that they are not involved in modern day slavery or human trafficking.
Policies on Modern Slavery
As we develop and build our business, we are actively seeking to develop and improve our internal controls with regard to selecting and engaging suppliers. These will include specific instruction on checking potential suppliers’ approaches to modern slavery. Additionally, as we develop our Contracts Policy, it will also advise that no contract can be entered into by Commercial and Northern which breaches any law or regulation.
Members of the Commercial and Northern Ltd Board and staff are able to report any suspicion of modern slavery or human trafficking under our Whistleblowing policy.
Clients and Borrowers
As part of our business lending, we will develop social risk policies to ensure that through our borrowers, our lending does not have unacceptable impacts on people, including the abuse of human rights, the use of forced labour, harmful or exploitative child labour, human trafficking, abuse of workers’ rights and health and safety legislation. If we find that borrowers are in breach of any such regulations, it may result in us ending or restricting our relationship with that borrower.
Modern Slavery Awareness
As we build our business, we will ensure that staff undertake regular training on the company’s and their own obligations with regard to modern slavery and human trafficking. Additionally, we are investigating how we may work with suppliers to provide training on these matters to them.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Commercial and Northern Ltd’s slavery and human trafficking statement for the year ending 31 December 2019.