Modern Slavery and Human Trafficking Statement
Hodge (in this context, Hodge Limited, Julian Hodge Bank Limited and Hodge Life Assurance Company Limited) is making this statement under the provisions of Section 54, Part 6 of the Modern Slavery Act 2015. This statement sets out the steps taken by Hodge to ensure that neither slavery nor human trafficking (together, ‘Modern Slavery’) occur within its own operations or supply chains.
Modern Slavery is defined by the Home Office as:
“The illegal exploitation of people for personal or commercial gain. Victims are trapped in servitude, which they were deceived or coerced into, and feel they cannot leave. It includes human trafficking. Common forms of exploitation include domestic servitude, sexual exploitation, forced marriage, forced criminality and forced labour”.
Hodge has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings and relationships.
Hodge is an independent, privately-owned financial services group operating from a single location, based in Cardiff. We employ nearly 200 people and all our activities are conducted within the United Kingdom.
Our mission, which underpins everything that we do, is to make life better for our customers, colleagues and communities by providing specialist lending, savings and retirement solutions in a manner that is fair, friendly and personal.
Our values and supporting policies reflect our commitment to act ethically and with integrity.
We have a whistleblowing policy which enables colleagues to report any concerns related to our business dealings. The policy is designed to ensure that matters raised under this policy are investigated thoroughly, promptly and confidentially and without fear of victimisation.
We have communicated this statement to all our colleagues to ensure there is a level of understanding of the risks of modern slavery to our businesses and to our supply chain. Awareness training is delivered as required, as part of our compulsory induction and ongoing compliance training for all colleagues.
National Living Wage / Low Pay
Hodge is committed to being a fair and reasonable employer and ensures that salaries remain competitive within its market through a variety of methods. We ensure that all colleagues are paid at least the national living wage rate, regardless of age.
Supply Chains – Outsourcing and Third Parties
Hodge considers that the financial services industry in the United Kingdom is a low risk industry in relation to modern slavery.
The majority of third-party relationships are with firms in the United Kingdom and EU and are therefore considered to be low risk based on jurisdiction.
As such, Hodge takes a risk-based approach to the engagement of third-party suppliers and will carry out due diligence checks on all suppliers where it believes there is a risk of exposure to modern slavery within their operations.
Governance and Risk Management
A governance and risk management framework is in place to support adherence to policies/procedures and to identify risks faced by Hodge.
This is based on a “three lines of defence” model which includes the front line being responsible for risk identification, assessment and mitigation; the second line providing oversight and the third line providing independent assurance.
This Statement is signed on behalf of the Board by David Austin, Managing Director