Modern Slavery Policy

1  Introduction

1.1 Scope

1.1.1 This statement is made by Mortgage Brain Limited, AE3 Media Limited and any and all other associated companies (the “Group”) and is reflective of the practices of the Group. This sets out the steps that the Group takes to combat and prevent all forms of modern slavery and human trafficking in the business and supply chains. This statement covers the Groups direct operations and supply chains.

1.2 Intended Audience

1.2.1 This document is intended to be read by all company colleagues and must not be provided to Third Parties without approval from the document owners (currently, the Senior HR Manager and / or the Chief Financial Officer (CFO)).

2  Group’s Structure and Business

The Group specialises in:

2.1 Software

2.1.1 Our offering provides comprehensive technology and data solutions for advisers, lenders, and business partners, covering the complete, end-to-end home ownership process.

2.2  Media and Events

2.2.1 We provide a knowledge hub for the mortgage industry and consumer personal finance market. We operate Your Money, Mortgage Solutions, Your Mortgage and events such as the British Mortgage Awards, the British Mortgage and Protection Senate and The Mortgage and Protection Event plus a number of other leading industry awards and conferences.

3  Engagements and Policies in Relation to Modern Slavery and Human Trafficking

3.1  The Group is committed to respecting internationally recognized human rights principles as defined by the United Nations Universal Declaration of Human Rights, the core standards of the International Labour Organisation and the Guiding Principles for the implementation of the United Nations “Protect, Respect and Remedy” Framework (Ruggie Principles).

3.2  The Group aims to ensure that (i) the Group does not cause or contribute to adverse human rights impacts and (ii) such impacts are addressed when they occur.

3.3  All employees are encouraged to report promptly any practices, actions or conduct that they believe are inappropriate or in danger of causing adverse human rights impacts through whistleblowing procedures.

4  Management of the Modern Slavery and Human Trafficking Risk in the Group’s Operations

4.1  The Group acknowledges its responsibility to respect human rights in its operations and conducts its business in compliance with applicable employment regulations in the jurisdictions in which it operates. In particular:

• the Group is committed to upholding the right of freedom of association and collective bargaining, as well as maintaining constructive labour management relations in every country in which it does business, and to doing so with due respect for different national approaches to social dialogue;
• the Group respects the rights of its employees to enjoy just and favourable conditions of work, including health and safety protections, and is committed to providing adequate information and training on health and safety and wellbeing issues.

4.2  In addition, the Group promotes diversity and inclusion by prohibiting any form of discrimination between current, past or prospective staff on diversity dimensions including age, disability, gender identity, ethnicity or race, sexual orientation, marital status or religion through its Diversity and Equal Opportunities Policy.

5  Assessment of the Groups Largest Suppliers and Due Diligence Process in Relation to the Groups Supply Chains

5.1  The Group ensures that it works with suppliers that meet the ethical standards expected. This includes refraining from using or accepting that their own suppliers and sub-contractors make use of, child labour (under 15 years old) or forced labour.

6  Questions and Information

6.1  If you want to ask a question about this statement, then please either speak to the Finance Director or any member of the Operating Board or the Senior HR Manager or your Colleague Council Representative.