Modern Slavery Statement | Cash Converters

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 2022 to 30 June 2023. 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, Cash Converters Group refers to Cash Converters UK Holdings Limited and any entities it owns or controls. This is because Cash Converters adopts a group-wide approach to ensuring 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 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 pawnbroking business based in Western Australia. The Cash Converters brand now has an international presence through a franchise network in a further 14 countries around the world.

In July 2023, Cash Converters acquired Capital Cash Limited, their largest franchisee, bringing 42 stores under their direct ownership. This established a corporate presence in the UK. This has now expanded to 47 company-owned stores, which now sell new and used goods in-store and online while also generating revenue through pawnbroking and buyback programs. The stores employ 285 permanent staff. Cash Converters (UK) Limited is the franchisor of a network of 143 franchised stores. The franchise network is not a controlled entity of Cash Converters. The franchises are independent entities subject to arms' length commercial arrangements implemented under franchise agreements, licencing the use of the Cash Converters trademarks.

Our supply chains

In the 2022/2023 financial year, the Cash Converters Group (which then excluded Cash Converters (UK) Stores Limited) spent £3.5m procuring goods and services from approximately 157 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: This includes leasing services and essential services such as air-conditioning maintenance, electricity, internet, pest control, cleaning, and security.

The group's supply chain is primarily based in the UK, with the exception of IT services, which are supplied via our Australian parent company. For our corporate stores, there is one US supplier and one supplier based in 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 2022/2023 financial year, all Cash Converters UK 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 corporate head office in High Wycombe and Support Centre in Runcorn. All employees are engaged under a written employment agreement that 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 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. As noted above, we have 3 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 with 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 the 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 working conditions are hazardous.

Cash Converters recognises that its supply chain may directly or indirectly expose it to modern slavery risks. Mapping the supply chain through the various tiers of suppliers is necessary to identify and assess risk in 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 corporate head office and support centre, identifying any potential modern slavery risks in its operations and supply chain. This mapping program highlighted that the risk of modern slavery within Cash Converters' operations and supply chain is low. Cash Converters remains committed to the 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 help 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 control are also set out in more detail in the table below.

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.

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 has commenced work on preparing 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 Converters 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

	Request suppliers to provide their modern slavery statement (if available) or fill out the Cash Converters questionnaire, which the business then reviews.
	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.
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 laws and regulations.
	Third Party Governance Policy: This policy sets out the procedure for third-party suppliers, including all legal requirements that must be met to ensure compliance with financial and legal obligations.
	Third-Party Due Diligence Procedure - which sets out in detail the process for due diligence at onboarding and ongoing due diligence for Cash Converters providers and suppliers; 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: This policy 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.
Employment Practices	Cash Converters has robust human resources controls in place that cover all aspects of employment practice.
	All employees are engaged under a written employment agreement that 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 focused on continuing to build on the understanding of the risk of modern slavery in our operations and supply chain gained during previous reporting periods and developing controls to address those risks where required.

During the reporting period, Cash Converters:

Continued to provide modern slavery training modules, which must be completed annually. The modules enable Cash Converters to monitor and track the number of employees who have undertaken and successfully completed modern slavery training.
Updated policies and procedures to include and reflect modern slavery practices.
Enhanced due diligence on our suppliers by having a dedicated Procurement Manager and Partnership Manager in place.
Implemented global screening of suppliers for modern slavery.
Conducted a risk assessment of our international suppliers.
Continued with our robust employee practices.
Continued 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.
Conducted a risk assessment of new and existing domestic providers and suppliers.

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 24th April 2024.