Introduction from the Cash Converters UK Chief Executive Officer
This is a joint Modern Slavery Statement made pursuant to Section 54 of the Modern Slavery Act 2015 on behalf of Cash Converters UK Holdings Limited and its subsidiaries, Cash Converters (UK) Limited and Cash Converters (UK) Stores Limited (the Cash Converters Group) for the period 01 July 2023 to 30 June 2024. This statement sets out the actions taken by the Cash Converters Group this financial year, and those we continue to take, to assess and address modern slavery and human trafficking risks throughout our organisation and our supply chain.
In this statement reference to Cash Converters Group is used to refer to Cash Converters UK Holdings Limited and any entities which it owns or controls. This is because Cash Converters adopts a group-wide approach to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our group and in our supply chain.
This Statement has been approved by the Board of Cash Converters UK Holdings Limited on behalf of the Cash Converters Group. The Board of Cash Converters UK Holdings Limited and the Cash Converters Group have a zero tolerance for any form of modern slavery and in line with the United Nations Guiding Principles on Business and Human Rights, recognise the duty of the international community to protect human rights as well as the fundamental responsibility of businesses to play their part.
Organisation's structure
Cash Converters was founded in 1984 as a family owned and operated pawn broking business based in Western Australia. The Cash Converters brand now has an international presence through a franchise network in a total of 17 countries around the world.
In July 2023 the Cash Converters Group acquired its largest Franchisee company, Capital Cash Limited, which became Cash Converters (UK) Stores Limited. Capital Cash Limited had been operating stores across the UK for 20 years and at the time of acquisition were operating 42 stores. This acquisition gives Cash Converters a corporate store footprint in the UK. Revenue from the now 46 corporate owned stores is derived from the retailing of new and second-hand goods both in store and online, as well as interest from pawnbroking and fees from our buyback product.
Cash Converters (UK) Limited is the franchisor of a network of 147 franchised stores The franchisees are independent entities subject to arms’ length commercial arrangements implemented under franchise agreements, licencing the use of the Cash Converters trademarks, rather than entities under the control of Cash Converters.
In the 2023/2024 financial year the Cash Converters Group procured goods and services from approximately 385 suppliers. Spending across the group can be broadly categorised into the following areas:
· Information Technology: which includes software, professional IT services, infrastructure, telecommunications, support, and maintenance.
· Corporate Services: which includes advisory, finance and legal services, insurance, office supplies and records management.
· Marketing which includes marketing and advertising services.
· Property and Facilities Management: which includes leasing services, essential services such as air-conditioning maintenance, electricity, internet, pest control, cleaning, and security.
· Retail stock: our suppliers include suppliers of a broad range of products for retail sale in our corporate operated stores. In the reporting period has included electronics, jewellery, musical instruments and handbags to name a few.
The group’s supply chain is based primarily in the UK with a limited number of overseas suppliers. Cash Converters IT services are supplied via our Australian parent company. The few overseas Tier 1 suppliers are based in low-risk jurisdictions such as United States of America and France,
Operations
Cash Converters considers the risk of modern slavery within its direct business operations as low given the highly regulated industry in which the business operates and the relatively skilled nature of its employees.
During the reporting period all 336 Cash Converters Group employees were permanent staff, with no casual staff or contractors. Casual or fixed-term staff are employed to allow for flexibility during peak business periods and are predominantly employed where shorter-term labour requirements are needed (i.e. to cover a period of absence for a permanent employee). Contractors are largely used across the business for longer-term consultation, project work or provision of Marketing services, predominantly at Cash Converters head office in High Wycombe and Support Centre in Runcorn. All employees are engaged under a written employment agreement which sets out clear terms including pay and hours of work. Cash Converters’ UK operations focus primarily on second-hand retailing, pawnbroking and buy backs to a UK customer base. These products and services are not considered high risk in terms of modern slavery and Cash Converters does not operate within a high-risk jurisdiction (by reference to the Walk Free Global Slavery Index). Given the nature of the financial products offered and the target market, Cash Converters considers its exposure to modern slavery risks through its products and services to be low risk.
Supply Chain
Cash Converters has taken a risk-based approach to assessing of modern slavery risks within its tier 1, 2 and 3 suppliers, building on the work already carried out for our suppliers. This assessment has been conducted based on the geographic risk, vulnerability, and country governance for modern slavery. We have 4 suppliers in total that are outside the UK in low risk rated jurisdictions. All domestic and international suppliers have been screened against modern slavery lists, with no adverse findings. All suppliers are within inherently low risk jurisdictions from a modern slavery perspective according to the Walk Free Global Slavery Index. Cash Converters have again identified the three areas of our supply chain which present an inherently higher risk of modern slavery, those areas are:
Cleaning, and security
These supplies present a higher inherent risk of modern slavery due to the relatively low-skilled and labour-intensive nature of the work. Staffing in these industries may also be relatively informal and insecure and is often serviced by a migrant workforce. There have also been reported instances of modern slavery like practices in these industries, particularly the cleaning industry.
Electronic products
These supplies present a higher inherent risk of modern slavery because of the undesirable and at times hazardous working conditions (and without adequate safety equipment). As the electronic sector seeks to respond to rapid advancement in products and demand, workers in this industry can often be subject to extended hours without proper remuneration. The substantial migrant workforce, use of casual labour and labour agents present further inherent risks of modern slavery in the industry.
Gold and diamonds
The Global Slavery Index identifies mining as one of the sectors at risk of modern slavery, with risks specifically associated with mining of gold and diamonds in certain geographical areas, usually characterised by high levels of conflict, corruption or weak governance. Mining is a labour intensive area, where again working conditions are hazardous.
Cash Converters recognises that through its supply chain, it may be directly or indirectly exposed to modern slavery risks. Mapping the supply chain through the various tiers of suppliers is necessary to identifying and assessing risk on areas of the business that could potentially cause, contribute to, or be directly linked to modern slavery through Cash Converter's operations and supply chain.
During the reporting year Cash Converters updated its risk assessment of its suppliers, corporate store operations, franchise store operations and its corporate head office and support centre, identifying any potential modern slavery risks in its operations and supply chain. This mapping program highlighted that risk of modern slavery within Cash Converters operations and supply chain to be low. Cash Converters remains committed to ongoing development of the program and continuous risk assessments to highlight and assess any risks of modern slavery that may arise within its operations and supply chains.
Controls to mitigate modern slavery risks
Cash Converters is continuing to implement and maintain a programme of controls in order to address modern slavery risks in its operations and supply chain. The areas of focus can be broadly categorised as follows:
· Values: Cash Converters is driven by three core values which helps to build a culture of passion respect and determination to do the right thing.
· Increasing supplier controls: This includes appropriate modern slavery provisions and protections in supplier agreements.
· Continuing to develop policy frameworks: this includes reviewing, assessing and (as necessary) uplifting Cash Converters' existing policy framework from a modern slavery provisions and protections perspective.
· Improving employee awareness of modern slavery: this includes modern slavery training modules to ensure greater awareness.
The areas of controls are also set out in more detail in the table below.
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Values |
During this reporting period, Cash Converters continued to promote its core values. These values are set out below: · We're real people who are passionate and proud: We’re genuine, friendly and from your neighbourhood. We’re passionate and proud to be here helping our customers. · We're caring and respectful: We’re here to listen and find ways to help make things possible, supportive of our customers and our colleagues. There’s no judgement here. We treat everyone as an individual. · We're tenacious problem solvers: We don’t back down. We always try our best to help others, no matter how hard the task seems. These values help to continually support a culture of integrity, respect, and willingness to always try our best. This includes calling out misconduct or any incidents that may give rise to potential modern slavery risks. |
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Supplier Controls |
Modern Slavery Contractual Clauses Suppliers are required to enter into a written agreement with Cash Converters with respect to supply arrangements or other engagements. Cash Converters recognises the value of incorporating a suite of modern slavery specific clauses into its supplier contracts and commenced work on preparing a such clauses as appropriate. This continues to be a focus for the future reporting periods.
Supplier Due Diligence and Risk Assessment · Cash Converters is continually improving processes around supplier engagement and associated due diligence requirements. During the reporting year Cash Converters conducted a refresh of its previous risk assessment and introduced supplier screening and further enhanced supplier due diligence. The work conducted includes the following: · Considering human rights and modern slavery risks within the Company’s operations, supply chains and other business relationships. · An assessment of each risk based on Cash Converter’s risk assessment matrix and the likelihood of potential or actual modern slavery impacts. · International suppliers risk-based assessment conducted. · Screening of all suppliers (domestic & International) against modern slavery lists including: § Exploitation of Children § Forced and Slaved Labour § Human Rights Violation § Human Trafficking § Sexual Exploitation § Smuggling · Requesting suppliers provide their modern slavery statement (if available) or fill out Cash Converters MS questionnaire, which are then reviewed by the business. The risk assessments and screening have concluded that the modern slavery risks within Cash Converter’s operations and supply chains are low as the operations of the Group are conducted in low modern slavery risk countries such as the UK and Australia.
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Policy Framework |
Cash Converters' existing policy framework which applies to all employees and suppliers includes: · Code of Conduct - which sets out the expectation that all Cash Converters employees adhere to the highest standards of personal and professional business conduct, ethics, and integrity, including compliance with all applicable law and regulations; · Third Party Governance Policy - which sets out the procedure for third party suppliers, including all legal requirements which must be met in order to ensure compliance with financial and legal obligations; · Third Party Due Diligence Procedure – which sets out in detail the process for due diligence at on-boarding and ongoing due diligence for Cash Converters providers and suppliers; · Procurement Policy – which sets out the procedures for selection of a supplier of goods or services to ensure we engage with those who meet our expectations as to ethical business practices generally and specifically those matters set out in our Supplier Code of Conduct · Purchasing and Invoicing Policy - which defines standard methods and procedures for purchasing and invoicing including that those procedures must comply with all legal requirements and those implementing them must adhere to ethical principles such as transparency, fairness, accountability; and · Whistleblower Policy - which sets out Cash Converters' commitment to the highest standards of conduct and ethical behaviour in all business activities, and to promote and support a culture of honest and ethical behaviour, corporate compliance, and good corporate governance in which individuals can safely raise concerns about any misconduct. |
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Employment Practices |
Cash Converters has robust human resources controls in place which cover all aspects of employment practice. All employees are engaged under a written employment agreement which sets out clear terms including pay and hours of work. From time-to-time Cash Converters may employ non-resident workers subject to that person having the appropriate authorisation and right to work in the UK. Cash Converters takes particular care to ensure that any foreign worker is engaged on the same terms and conditions as UK citizens and permanent residents. Cash Converters has developed an online modern slavery module, which has been incorporated into mandatory annual training, as part of its e-learning framework |
Assessment of effectiveness
· During this reporting period Cash Converters has: Continued to provide mandatory modern slavery training modules. The modules enable Cash Converters to monitor and track the number of employees who have undertaken and successfully completed the annual modern slavery training.
· Reviewed and evolved policies and procedures to enable us to continue to identify and mitigate the potential risk of modern slavery in our supply chain
· Established clear reporting lines where potential risks are identified – where the risk is within the supply chain the information is reported to the Head of Risk and Compliance initially, escalated to the Risk Committee and where appropriate to Risk Committee will report to the Board. Any risk within our employees is reported via our whistleblowing process.
· Continued with our robust employee practices.
· Continue reviewing and assessing the number of supplier agreements across the Group’s supply chain that require the incorporation of appropriate modern slavery provisions and protections.
· Continued risk assessments of new and existing domestic and international providers and suppliers across the Group.
· Working closely with our parent company Cash Converters International in Australia to utilise resources and align standards across the global Cash Converters business
Cash Converters will continue to look for and report on ways in which it assesses effectiveness in future reporting periods.
Consultations
Cash Converters has worked with and consulted senior management within the Group in preparing this modern slavery statement. Those senior managers sit across core business operations and subsidiaries.
Franchisees are independently owned and operated entities.
Cash Converters (UK) Limited and Cash Converters (UK) Stores Limited are wholly owned subsidiaries of Cash Converters (UK) Holdings Limited. This statement was approved by the Cash Converters UK Holdings Limited Board on 23 October 2024.
