Anti-Slavery & Human Trafficking Statement

Introduction

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that Happy Motor Finance Ltd ("we", "us", "our") has taken and continues to take to ensure that modern slavery and human trafficking are not taking place within our business or our supply chain.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

We have a zero-tolerance approach to modern slavery. 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.

Our Business

Happy Motor Finance Ltd is a credit broker authorised and regulated by the Financial Conduct Authority. We operate in the United Kingdom and provide credit broking services, introducing customers to a panel of lenders for the purpose of obtaining motor vehicle finance. Our business activities include:

• Credit broking and intermediary services
• Customer service and support
• Marketing and lead generation
• Website development and maintenance

Our Supply Chains

Our supply chains include:

• Lender partners: FCA-regulated lenders who provide motor finance to our customers
• Technology providers: Software and platform providers who support our business operations
• Marketing partners: Agencies and platforms used for advertising and lead generation
• Professional services: Legal, accounting, and compliance advisers
• Office and facilities: Landlords, utilities, and maintenance providers

Given the nature of our business as a financial services firm operating primarily in the UK, we consider our risk of exposure to modern slavery to be relatively low. However, we remain vigilant and do not take a complacent approach.

Our Policies

We operate a number of internal policies to ensure we are conducting business in an ethical and transparent manner. These include:

Anti-Slavery Policy

We have an internal Anti-Slavery Policy that sets out our commitment to preventing modern slavery and human trafficking in our business and supply chains. This policy applies to all persons working for us or on our behalf in any capacity, including employees, directors, officers, agency workers, contractors, consultants, and business partners.

Recruitment and Employment Practices

We operate robust recruitment processes, including:

• Verifying the identity and right to work in the UK for all employees
• Ensuring all employees have a written contract of employment
• Paying at least the National Living Wage to all employees
• Ensuring working hours comply with the Working Time Regulations 1998
• Using only reputable employment agencies that comply with employment legislation
• Conducting appropriate background checks on new employees

Whistleblowing Policy

We have a Whistleblowing Policy that encourages all employees, contractors, and business partners to report any concerns about unethical behaviour, including suspected modern slavery. We ensure that anyone who raises a genuine concern in good faith will not be subjected to any detriment or disadvantage as a result.

Code of Conduct

Our Code of Conduct sets out the standards of behaviour expected of everyone who works for or with us. This includes a commitment to treating people with dignity and respect and not tolerating any form of exploitation.

Due Diligence

We carry out due diligence on our suppliers and business partners to assess the risk of modern slavery. Our due diligence processes include:

• Assessing the nature and location of our suppliers' operations
• Reviewing suppliers' own modern slavery statements and policies where available
• Ensuring key suppliers and partners are regulated or accredited by relevant bodies
• Including anti-slavery provisions in our contracts with suppliers where appropriate
• Conducting periodic reviews of our supply chain to identify and mitigate risks

As our lender partners are FCA-regulated firms, they are subject to their own regulatory obligations, including requirements around ethical conduct and governance. We consider this to provide an additional layer of assurance.

Risk Assessment

We have assessed the risk of modern slavery in our business and supply chain. Key findings include:

• Low risk: Our core business operations are conducted in the UK by directly employed staff, and our primary supply chain consists of FCA-regulated financial institutions and established technology companies.
• Areas of vigilance: We remain attentive to risks in areas such as third-party marketing services, outsourced IT services, and office cleaning or facilities management where labour exploitation can occur.

Training and Awareness

We provide training and information to our staff to ensure they understand the risks of modern slavery and know how to identify and report potential issues. This includes:

• Awareness training for all new employees during their induction
• Periodic refresher training for all staff
• Specific guidance for staff involved in procurement and supplier management
• Clear communication of our whistleblowing and reporting procedures

Key Performance Indicators

We measure the effectiveness of our anti-slavery measures through the following key performance indicators:

• Completion rates for modern slavery awareness training
• Number of supplier due diligence assessments completed
• Number of reports or concerns raised through our whistleblowing procedures
• Outcome of any investigations conducted

Reporting Concerns

If you suspect or become aware of any instance of modern slavery or human trafficking in our business or supply chain, we encourage you to report it. You can:

• Contact us at info@happymotorfinance.co.uk
• Use our internal whistleblowing procedures (for employees and contractors)
• Contact the Modern Slavery Helpline on 08000 121 700 or visit modernslaveryhelpline.org
• Report to the police by calling 101 (or 999 in an emergency)

Our Ongoing Commitment

We are committed to continuously improving our practices to combat modern slavery and human trafficking. We will:

• Regularly review and update this statement and our anti-slavery policies
• Continue to assess the risk of modern slavery in our business and supply chain
• Enhance our due diligence processes as our business grows
• Engage with our suppliers to promote awareness and compliance
• Take appropriate action against any supplier found to be involved in modern slavery

Board Approval

This statement has been approved by the directors of Happy Motor Finance Ltd and will be reviewed and updated annually.