Modern Slavery Statement

Introduction

At Shire Leasing Plc and Shire Securities Limited (“Shire”) we are committed to upholding the highest standards of ethical conduct, corporate governance, and human rights protection. We recognise the importance of compliance with the Modern Slavery Act 2015, particularly section 54, and are committed to preventing acts of modern slavery and human trafficking within our organisation and throughout our supply chains. We aim to ensure full transparency in our business practices, making sustained efforts to identify and mitigate slavery and human trafficking risks across all areas of our operations.

Shire provides funding solutions to UK SMEs for business purposes. We have proudly supported over 66,000 UK businesses to acquire finance to grow, with SMEs forming 99% of our customer base. Due to the nature of our business, we have a low risk of modern slavery in our business and supply chains.

Shire’s customers and suppliers are all registered to trade in the UK.

 

Scope and Application

This policy applies to all individuals working for or on behalf of Shire. The policy extends to all supply chains, products, services, and business operations. Definitions As defined by section 54 of the Modern Slavery Act 2015, modern slavery comprises the following offences:

• Slavery: The exercise of any or all of the powers associated with the rights of ownership over another person.

• Servitude: The obligation to provide services under coercion, where a significant restriction is placed upon an individual’s freedom.

• Forced or Compulsory Labour: Work or services demanded from an individual under the threat of penalty or harm, without voluntary consent.

• Human Trafficking: Arranging or facilitating an individual’s travel with the intent of exploitation, whether or not the individual has consented to the travel.

 

Policy Statement

Shire adopts a strict zero-tolerance approach to modern slavery and human trafficking. We are committed to complying with section 54 of the Modern Slavery Act 2015 and implementing systems and controls to prevent modern slavery in our business operations and supply chains. We pledge to continually evaluate and adapt our practices to ensure all activities associated with our organisation adhere to the highest ethical standards. We prohibit the exploitation of individuals or any acts of human trafficking directly or indirectly related to our operations. To meet our obligations under section 54, we commit to transparent business processes, robust risk mitigation measures, and effective collaboration with suppliers, employees, and stakeholders.

 

Procedures

1. Supplier Due Diligence Protocols

To ensure modern slavery risks are mitigated within our procurement and supplier relationships, we will:

  • Conduct initial assessments of all suppliers prior to engagement, leveraging due diligence mechanisms such as supplier self-assessment questionnaires and auditing frameworks.

  • Where appropriate meet with our suppliers to gain a better understanding of their business and to see how they operate.

  • Maintain detailed records of assessments and audits.

  • Not trade with any supplier where we become aware they have slavery or human trafficking within their business.

2. Recruitment Practices

We will ensure fair and ethical recruitment practices through adherence to the following principles:

  • Recruitment agents will be subject to vetting by our HR department and added to an approved list, with periodic reviews and audits.

  • Individuals recruited directly by Shire or through recruitment agents will never be required to pay fees to facilitate their employment.

  • Transparent contracts language will be offered prior to employment, detailing all rights, obligations, and terms.

 

Training and Awareness

We recognise that consistent training is key to mitigating modern slavery risks. We are committed to ensure that we raise awareness with our staff to support them in their understanding and how they can report any concerns that they may have.

We are committed to supporting our staff and creating a working environment that is respectful of all. We have a number of policies that set the framework for our approach including:-

  • Employee Charter

  • HR policies including equality, diversity and inclusion policy

  • Recruitment policy

  • Ethics policy

  • Whistleblowing policy

Our efforts are supported by our People, Profit, Planet Committee (“PPP”) which meets monthly and sets the business sustainability strategy, focused on adding value and creating social, environmental and economic outcomes whilst achieving our company mission.

 

Reporting and Transparency

We provide robust reporting mechanisms, including whistleblowing procedures, to ensure that any concerns regarding modern slavery are addressed promptly. Employees, suppliers, and stakeholders may report instances or suspicions of non-compliance on a strictly confidential basis.

 

Monitoring and Review

This statement and policy, along with its associated systems and procedures, will be reviewed annually or more frequently as necessary in response to changes in legislation, emerging risks, or material changes within our supply chains.

 

This statement has been approved by the Board.

August 2025

 

Jane McLintock

Legal and Compliance Director

Shire Leasing Plc