Modern Slavery Statement 2020
Where we use we, us, or Lowell in this statement, we mean Lowell Financial Ltd (company number 04558936) on behalf of itself and each of the following UK companies:
- Lowell Portfolio I Ltd (Company number 04857418)
- Lowell Solicitors Limited (Company number 08647091)
- Fredrickson International Limited (Company number 02679522)
- Simon Bidco Limited (Company number 09709443)
- Metis Bidco Limited (Company number 07652466)
- Lowell UK Shared Services Limited (Company number 08336897)
- Lowell Group Shared Services Limited (Company number 08647094)
We are now publishing Lowell’s fourth slavery and human trafficking statement in accordance with section 54 of the Modern Slavery Act 2015 for the financial period 1 January 2019 to 31 December 2020. This statement sets out the work that we have undertaken to develop our systems and processes to increase transparency and eradicate the risk of modern slavery in our business and throughout our supply chains since we published our third modern slavery statement.
Our business is one of the UK’s largest credit management companies with a mission underpinned by our ethical and effective core values which aids our mission to make credit work better for all.
Lowell operates across nine different European countries. Our business in the UK is comprised of a number of legal entities, and are in some cases authorised and supervised by regulatory bodies.
We are proud to work with our clients, of which include some of the largest and most respected companies in the UK. We continue to be drawn from a wide range of organisations including banks, retailers and credit card, mobile phone, home shopping and utility (gas, electricity and water) companies and our business development function continually work to create new partnerships aligning and exceeding our current high professional and ethical standards.
Working at Lowell is about collectively pursuing our vision to make credit better for all, striving to deliver a great experience for our customers and having strong regulator and client relationships through which we are changing the conversation about debt.
We have nearly 1800 colleagues in Leeds where we continually aim to create a place where everyone wants to work with high levels of colleague engagement and pride. It is extremely important to us that we have a positive work culture where there is trust, accountability and collaboration.
We make sure that we comply with all relevant employment legislation relating to colleague terms and conditions, offering salaries for our entry roles over and above National Minimum Wage. We are an equal opportunities employer, diversity and inclusion is part of our people agenda, and we strive to provide a flexible and competitive compensation and benefits package. We are a highly regulated business and key ‘reward’ decisions are governed through our formal remuneration committee.
We promote a great working environment and support the physical and mental wellbeing of colleagues through a number of initiatives as part of our UK people and culture strategy. We have a continual focus on growth and development by providing a suite of relevant learning provisions tailored to individual needs and in line with our corporate strategy.
Working With Our Suppliers
We have expertise in a number of credit management areas including, debt purchasing, third party collections, litigation based collections, business process outsourcing, data analytics, credit management and other value added services.
In order to support the quality and standard of the services we provide to our clients, customers and colleagues, we procure a range of goods and services including but not limited to information technology services, payment & invoice services, catering and cleaning services. The Lowell supply chain is predominantly based in the UK and EU. All of our contractors and suppliers are required to work to the same high professional and ethical standards that we apply to our own business.
Our procurement process has continued to mature over the last 12 months. We have rolled out our new Third Party Management framework which has included the establishment of our Third Party Management Forum.
Due diligence is carried out on all new suppliers and our existing suppliers are subject to ongoing monitoring. A risk assessment is carried out for each supplier and they are categorised as posing a high, medium or low risk of modern slavery taking place in their business. This determines the level of ongoing monitoring for that supplier, including detailed audits and site visits for additional assurance where appropriate. Our risk assessments were re-validated in 2019.
Our due diligence and ongoing monitoring processes were also reviewed and enhanced in 2019 as part of the roll out of the new Third Party Management framework.
We incorporate robust anti-slavery provisions within our contractual arrangements as a matter of course.
We will continue to review, update and improve our procurement processes over the next 12 months.
We have a number of policies in place, which support our anti-slavery work, including our procurement policy, speak up policy (which is our whistleblowing policy), equal opportunities policy, recruitment policy, anti-bribery policy and corporate social responsibility policy.
In particular, our speak-up policy encourages colleagues to report any concerns about malpractice or wrongdoing. We also work with an independent third party provider to provide colleagues with an additional option to raise potential issues and to ensure that they feel able to do so on an anonymous basis. We are committed to the highest possible standards of openness, probity and accountability and we expect our colleagues and others that we deal with, who have serious concerns to come forward and voice those concerns.
We will review, update and, where appropriate, develop and improve our policies over the next 12
Objectives and Key Performance Indicators
Last year we set ourselves the objectives of:
- maintaining and updating, as appropriate, our supplier risk assessment procedures to improve
our ability to identify and assess potential areas of risk, particularly in relation to modern slavery,
in our supply chains; and
- reviewing and updating our supplier oversight programme to ensure that an appropriate level of
monitoring is applied to our suppliers depending on the level of risk that they pose
We achieved both of these objectives through the roll out of our new Third Party Management framework.
We also continued to incorporate anti-slavery provisions into our contracts with our suppliers.
Our objectives for the next 12 months are to:
- review and update our colleague reward packages;
- continue to embed and mature our Third Party Management framework; and
- identify any additional training for procurement and HR colleagues in particular.
Given the nature of our objectives, we do not believe that it is appropriate at this time to set key performance indicators in respect of our ongoing work in relation to modern slavery. This will be kept under review and we may adopt key performance indicators in the future.
This slavery and human trafficking statement for the financial year ending 31 December 2019 has been approved for and on behalf of all of the companies named at the beginning of this statement.
Managing Director, UK
Approved on 26 June 2020