About this statement

This Statement is made pursuant to Section 54 of the United Kingdom Modern Slavery Act 2015 (the Act). The Act requires all companies operating in the United Kingdom (UK), to disclose information regarding the steps taken to eradicate slavery and human trafficking from their business and global supply chains.

This statement describes our business structure, relevant policies, and ongoing efforts designed to reduce the possibility that slavery and human trafficking occur in our business or global supply chains. In addition to satisfying our obligations under the Act, we intend to use this statement to enable shareholders, consumers, and suppliers to make informed choices about the companies they support.

Our Business

GAIN Credit, Inc. is a market-leading, alternative-lending, fintech company focused on creating compelling value propositions that empower the underserved with responsible access to credit, employing around 250 people, spread across Europe, India and the United States of America, servicing consumers and businesses. Our primary market focus is currently the UK, where we operate two brands: “Drafty” and “Lending Stream”. Drafty provides alternative credit options to near prime customers, while Lending Stream caters to sub-prime customers. We also offer credit-broking activities in the UK.

Our Commitment and Values

Gain Credit employs people from diverse backgrounds representing a range of races, religion, cultures, political philosophies, and languages. This diversity embodies the company’s respect for human rights and the dignity of our people. Our values are fundamental to how we relate to each other and to all those with whom we interact. As a global organisation, we recognise our responsibility to apply a strong and consistent approach to eliminating the risk of forced slavery and human trafficking in our business and in our supply chain.

Gain Credit is committed to promoting inclusivity for our consumers and employees. We actively promote and support Diversity, Equity and Inclusivity in our workplace and all of our employee policies and practices imbibe these principles. As an equal opportunity employer, some of these measures include, supporting flexible work arrangements, zero tolerance for harassment based on any protected characteristic and offering inclusive benefits, such as parental leave for all genders. Our employment practices on recruitment, rewards and career progression promote equity and we ensure that employees are treated fairly respecting their freedom, security, and dignity, irrespective of their age, belief, religion, caste, creed, gender, gender identity, marital or civil partnership status, political opinion, race, sexual orientation, native language, physical disability, or any other characteristic protected by applicable law.

In recognition of our employment practices, Gain Credit has also been certified as a Great Place to Work in India.

Risk assessment and management

As part of our onboarding process, employees and consultants are subject to a background verification while companies and other third parties go through a procurement process as explained below..

Expectations of our People

Gain Credit’s standards of workplace conduct applies to all employees and sets out our standards and expectations for both our employees’ behaviour and our business practices. Our standards are the reassertion of the Company’s commitment to conducting its business ethically and to observing applicable laws, rules, and regulations.

Each employee is a custodian of the Company’s good name and has a personal responsibility to ensure that their conduct protects and promotes these standards and the overall spirit of ethical conduct.

In conjunction with our workplace conduct standards, Gain Credit operates a Whistleblowing / Speak-up policy to enable our employees to speak up without fear of reprisal and bring to the attention of the Management any information on any act which compromises our commitment towards preventing Modern Slavery and human trafficking.

Expectations of Our Suppliers

Gain Credit seeks to maintain the highest standards throughout our global operations and is committed to acting with integrity in all our business relationships. We expect the same standards of business integrity of our suppliers and business partners.

Gain Credit suppliers are assessed as part of our procurement processes to screen and  onboard the third parties with which we choose to do business.

If a screening shows potential problems, we work with the business partner on a case-by-case basis to identify underlying issues and to remedy them to our satisfaction or we will not engage with that supplier. Our contracts have provisions which gives us the right to terminate the relationship in cases of breach of applicable laws or the contractual obligations.

Remediation

If instances of modern slavery or human trafficking are discovered within our business or supply chains, Gain Credit is committed to taking swift and decisive action. This may include terminating relationships with suppliers, treating such acts by employees as a misconduct and handling it under the disciplinary procedures, re-evaluating business practices to strengthen internal controls, and, where necessary, reporting instances to relevant authorities.

Training on modern slavery and trafficking

All existing employees and new hires are expected to read through this Statement, undergo trainings and refresher sessions on our Company policies including that of Modern Slavery, Anti Money Laundering and Anti-Bribery & Corruption on an annual basis and acknowledge their understanding of the risk of modern slavery and human trafficking and affirm their willingness to comply with the principles and policies outlined in it.

Social Impact and Sustainability

Gain Credit aspires to drive trust, innovation, performance, and partnership, and support our business strategies as well as collaborate with our people to support the communities in which we work.

Gain Credit endeavours to conduct its business in a sustainable manner and supports social causes in the areas where it operates. Gain Credit has undertaken initiatives to provide educational support to underprivileged children from downtrodden communities, differently-abled children, and special schools in India. Gain Credit has also supported disaster relief activities and livelihood support for women.

Looking Ahead

We plan to continue taking steps to strengthen our commitment to the Act and prevent slavery and human trafficking in our business and supply chains.

This will be done by evaluating our policies, processes, and procedures as appropriate in light of evolving best practices. We will continue to raise awareness and educating our employees, on how to identify signs of human rights violations and their role in upholding our commitment to human rights.

Statement

This statement has been approved by the board of directors on 30 January 2024 and is made on behalf of Gain Credit, Inc. pursuant to section 54 of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 2023. This statement is reviewed annually.

 

Mark Fiander

Group CEO of Gain Credit