Enra policy

Modern Slavery Statement

A) Organisation

This statement applies to all companies within and associated with Enra Group Ltd and its subsidiaries (referred to in this statement as ‘The Group’). The information included in the statement refers to the financial year 2020.

B) Organisational Structure

There are two offices with the principal office being: 3rd Floor, Premiere House, Elstree Way, Borehamwood, Hertfordshire, WD6 1JH. The Business Development Team are peripatetic. The Group consists of 3 divisions within the organisation; Broking & Lending.

The organisation is controlled by a Board of Directors.

The main activity carried out by the organisation is specialist mortgage advice, packaging and lending services. The organisation performs the activities of the aforementioned via our offices based in Borehamwood and Gerrards Cross, digital marketing activities and business development teams. The demand for our services is relatively consistent throughout the year.

The labour supplied to the Group in pursuance of its operation is carried out wholly within the United Kingdom.

C) Definitions

The Group considers that modern slavery encompasses:

  • Human trafficking;
  • Forced work, through mental or physical threat;
  • Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
  • Being dehumanised, treated as a commodity or being bought or sold as property;
  • Being physically constrained or to have a restriction placed on freedom of movement.

D) Commitment

The Group acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Group understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Group does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Group in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Group strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation.

E) Supply Chains

The Group’s key supply chains are provided by professional service firms, based entirely in the UK. No sub-contracting is permitted. One IT development supplier has recently opened an office in Barcelona where in due course certain IT development may be undertaken under the management of the UK office.

Banking services are provided by UK mainstream banks which may use call centres operating outside of the UK.

F) Potential Exposure

The Group considers that it has minimal exposure to the risk of slavery and human trafficking due to the nature and location of its offices and key supply chains.

G) Steps

In accordance with section 54(4) of the Modern Slavery Act 2015, the Group undertakes due diligence on all suppliers to ensure that modern slavery is not taking place.

The due diligence processes on all suppliers includes a review of key policies and are subject to sign off by the Head of Compliance, Operations Manager and CFO before any onboarding of suppliers. Regular reviews of supplier arrangements are undertaken.

The Group has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery. Where such an instance is found to have occurred the relationship will be terminated immediately.

Additionally, the Group maintains a whistleblowing policy, corporate & social responsibility policy and diversity & equality policies as well as a remuneration policy providing for fair and transparent methods for existing and prospective staff pay.

To ensure adherence to Group’s commitments set out in this statement, ongoing monitoring of suppliers will be undertaken ensuring reference is made to adherence to the Modern Slavery Act in supply contracts, internal policy review are completed at least annually and staff salaries and remuneration are reviewed regularly.

Board review of the Group’s Corporate and Social Responsibility policy will also contribute to the compounding of this statement into the Group’s culture.

H) Slavery Compliance Officer

The Group has appointed the CFO as the Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Group obligations in this regard.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

This statement has been signed by Emily Gestetner, Group Chief Financial Officer, and approved by the Enra Group Board of Directors