Modern Slavery Statement

This statement is made pursuant to the Modern Slavery Act 2015 and sets out the steps we take to ensure that slavery and human trafficking is not taking place in our supply chains or any part of our business. This is the first year we have produced a modern slavery statement.

Who we are:

Ultimate Finance Group Limited and its subsidiaries, Ultimate Finance Limited, Ultimate Asset Finance Limited and Ultimate Bridging Finance Limited (”Ultimate Finance”) are companies registered in England and Wales.  The purpose of Ultimate Finance is to provide asset based lending services to SMEs within England, Wales and Scotland by way of working capital, asset finance and bridging finance. Ultimate Finance is committed to maintaining a non-discriminatory and respectful working environment for its staff which is reflected in its Responsible Business Report. It is also committed to ensuring that there is no form of slavery or human trafficking within its organisation and looks to ensure this is monitored in relation, to the clients and third party suppliers it is engaged with.

We are proud to do business responsibly and ethically. We utilise the systems and controls we have in place in the business to ensure compliance with the Modern Slavery Act 2015 (MSA 2015) particularly focusing on our clients and third party suppliers.

How we do business:

The Ultimate Way – being the Funding Partner of Choice is about more than just the right funding at the right time. It’s about adding value to our employees, clients and introducers by building long lasting relationships. For our people it’s about being more than a job – we want to be a great place to work. A place where everyone feels valued, inspired and is rewarded.

Three core values shape Ultimate Finance and help us achieve our vision of being the Funding Partner of Choice.

• Decency – Doing the right thing by clients and introducers alike. Not about ticking boxes but looking at the bigger picture and finding the right solution.
• Brilliance – Going the extra mile. Empowering people so they have the authority and ability to make decisions and deliver the best possible service.
• Enterprise – All about evolution and innovation. Modernising our approach when and where necessary. Harnessing data and technology to improve speed, efficiency, and overall experience.

Ultimately what these values translate to is being a responsible business and that means not only making a difference to our clients, introducers, and our people but to the environment that we all live in.

Risks:

We will not work with any organisation that has been or is found to be knowingly involved in modern slavery.

The volume and nature of services we outsource are limited to administration services, technical data support, facilities management and cleaning. The overarching framework agreements, all have clear provisions regarding the MSA 2015.

All suppliers of goods and services are onboarded in line with our procurement policy and all terms and conditions are reviewed to ensure there are suitable provisions regarding the MSA 2015 and Criminal Finance Act 2015. Suppliers are also required to comply with our Suppliers Code of Conduct which sets out the standards we expect from them in relation to modern slavery.  The same approach is taken to any introducers we work with and our standard terms and conditions also contain provisions regarding modern slavery and financial crime.

All clients who onboard with us, are subject to stringent due diligence checks and this is carried on throughout the life of the clients with continued due diligence and monitoring including adverse media checks.  Clients assessed as high risk are subject to enhanced due diligence.

All colleagues are encouraged and reminded to raise any concerns that they may have either to their manager, or another manager and ultimately, our Financial Crime Manager. This is communicated via our ongoing internal communications programme and through mandatory e-learning training for all colleagues.

Whether in relation to our clients or our suppliers, we are committed to terminating any agreements where there are reasonable suspicions of, or, confirmed instances of modern slavery.

Governance, policies and training:

Any incidents of modern slavery will be reported and recorded and where appropriate entered into our Group Risk Register which is reviewed quarterly. Our approach to modern slavery will also be reviewed and documented in our annual Responsible Business Report as well as this annual statement.

We maintain the following policies and codes of conduct which are reviewed annually or in line with any amendments to legislation – whichever comes sooner:

• Modern Slavery policy
• Anti Bribery and Corruption additionally supported by a Gifts Register
• Anti Money Laundering
• Financial Crime
• Supplier Code of Conduct

In addition to training for modern slavery awareness, there is annual training and support for all colleagues in respect of Anti Bribery and Corruption, Anti-Money Laundering Compliance and Financial Crime.

Next steps

As at the date of this statement, we have had no incidents of modern slavery reported in connection to our clients or third party suppliers. However, as well as continuing our commitment to improving our business and our staff’s knowledge about modern slavery, we will continue to improve the safeguard and defences we have in place and raise awareness with our clients to help fight the eradication of modern slavery in all its forms.

Approved by the Board of Directors 1 August 2023