Introduction
Liberis is a global embedded finance provider, providing revenue-based finance to small and medium enterprises (SMEs) in the UK, Ireland, US, Sweden, Finland, Denmark, Czech Republic, and Slovakia. Our product provides revenue-based finance upfront to businesses who pay an agreed percentage of their card takings until the finance and fee is paid.
This statement describes Liberis’ approach to the detection and prevention of modern slavery. Liberis has a zero-tolerance approach to modern slavery and human trafficking, and we are committed to ensuring the business operates responsibly. At Liberis, we strive to always act with integrity and to conduct our business in a fair and transparent manner. This culture is driven from the top by our Board of Directors, Chief Executive Officer, and the wider Executive Leadership Team.
Policy Statement
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and 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 own suppliers to the same high standards.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.
Responsibility for Policy
The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The Director of Compliance has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains. You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions, and queries are encouraged and should be addressed to compliance@liberis.co.uk.
Our Employees
At Liberis, we take pride in having shared Liberis Behaviours embedded within the business, and the maintenance of those values are extremely important to us. Prior to joining Liberis, all employees are subject to background checks at onboarding and screening. They are also required to complete mandatory training covering a range of business compliance, anti-financial crime, and data protection modules.
Policies, Procedures and Processes
We have developed a suite of policies and procedures, supported by senior management, that encourage prevention of anti-slavery and human trafficking. We have the right incentives that are likely to influence positive behaviour within our organisation. Our relevant policies include those relating to:
We encourage both employees and people outside of our organisation to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains. You can do so by notifying the Director of Compliance at compliance@liberis.co.uk.
Supply Chain Management
Our supply chain is not complex and is primarily comprised of suppliers of technology and data suppliers, and office facilities. Additionally, Liberis works closely with several partners to offer the revenue-based finance product.
We recognise our responsibility to identify and address any potential violations of the Modern Slavery Act, and we therefore have robust vendor and partner due diligence processes which ensures all our suppliers operate in a way that is in line with Liberis’ Behaviours.
We do not tolerate slavery and human trafficking within our supply chains and would immediately terminate any relationship should we find evidence of this.
Risk Assessment
Given the nature of our business, the suppliers and partner Liberis works with we believe that Liberis is at a low risk of involvement in slavery and human trafficking.
We have not had any incidents of non-compliance with this Statement.
Rob Straathof, CEO
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