1. Introduction

 

This Statement is made by GRENKELEASING Ltd (UK) (‘GRENKE’/‘the Business’) in compliance with the Modern Slavery Act 2015.

 

The Business is committed to the eradication of any form of slavery and human trafficking within its business and supply chains. We adopt a zero-tolerance policy towards slavery, servitude, forced labour and/or human trafficking, and we work hard to assess and monitor all business relationships and employees to ensure fair and respectful treatment for all.

 

 

2. Policy Statement and Commitment

 

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.

 

We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

 

Whilst, given the nature of our business, modern slavery considerations are less likely to arise in our own business than that of other industries, we are still committed to tackling modern slavery wherever possible and comply with our disclosure obligations under the Modern Slavery Act 2015.

 

We expect the same high standards from our staff and those in our supply chain.  As part of our contracting processes, we expect prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude (whether adults or children). Through doing so, our supply chain are clear on our commitment.

 

 

3. Our Structure

 

GRENKE is a wholly-owned subsidiary of GRENKE AG, which is regulated in Germany by the Federal Financial Supervisory Authority. GRENKE AG is a controller within the meaning of the FCA Handbook.  Whilst GRENKE AG exercises oversight and supervision, GRENKE itself is largely autonomous in terms of its day-to-day operations, and this is especially so within the sphere of regulated consumer hire.

 

The Business is incorporated in England and Wales with the registration number 04539806 and the registered office address: Ground Floor, 2 London Square, Cross Lanes, Guildford, England, GU1 1UN.

 

The Business is regulated by the Financial Conduct Authority (FCA).

 

Since 2002, GRENKE has carried on business as a hire company with its sole focus being the long-term commercial sector of the rental market. GRENKE predominantly operates in the SME sector, although it does provide funding to large businesses.

 

GRENKE is based in the UK and only deals with UK Customers, although we may provide financial services to businesses that have ownership overseas.

 

We use various Partners to introduce new customers to our Business. All of these Partners undergo due diligence and approval before they can access GRENKE products or introduce business to us. Our risk assessment for our Partners is completed annually thereafter.

 

As part of this due diligence, we will consider the risks associated with Modern Slavery.

 

All of our Customers and Partners are based in the UK and all Customer Relationships are introduced through our Partner network.

 

Through this risk-based approach, when engaging with any Customer or Partner that does not meet our criteria, we will be able to consider appropriate action to be taken. Furthermore, we will not enter into any financial transaction with a Third Party until the risk assessment has been completed and approved.

 

We review risk on an ongoing basis as risk changes or when information is brought to our attention that will require risk to be re-assessed. 

 

 

4. Our Approach

 

We have dedicated policies in the performance of Due Diligence and provide our staff with annual training on the requirements of the Business.

 

Due Diligence forms an integral part of our approach to risk and risk management. Due Diligence is performed on those involved in our Supply Chain including:

 

• Staff
• Suppliers of Services
• Partners
• Customers (to a lesser extent due to the relationship being held with the Partner who introduced the business).

 

Our focus is to remove any risk of Modern Slavery through our supply chain.

 

To assist with the Due Diligence process the Business has provided training to all staff on Modern Slavery which includes issues to consider, and action to take, in the event any form of Slavery is suspected in our supply chain.

 

If, as part of our Due Diligence, any issues of Modern Slavery are highlighted, they will be referred to, and dealt with, at the highest level within our Business. In the event the Business believes that an entity or person in our supply chain is in breach of the Modern Slavery Act 2015 we will immediately suspend all activity, investigate and where appropriate make reports to the relevant authorities.

 

We are proud to be an equal opportunities employer and we are committed to the provision of an approach which ensures equality in all of our dealings. We do not condone or tolerate any bullying, harassment or victimisation by any member of staff or any other person engaged with our Business.

 

The Business has both an internal compliance department and external compliance expertise to ensure we remain at all times compliant with all legislation and regulations applicable to our Business.

 

 

5. Training and Resounrces

 

As part of the Business’s compulsory annual compliance training, all staff are provided with training on:

 

• The issues arising from Modern Slavery.
• Their role in identifying Modern Slavery.
• How to identify issues.
• When and how to report such issues if they arise.
• The action the Business takes to prevent Modern Slavery.

 

All staff have access to a supervisor and can report any concerns of Modern Slavery to their line manager or confidentially via the Business’s Whistleblowing system.

 

Our HR and Compliance Departments (internal and external) are also available to discuss any issues should they arise.

 

 

6. Requests for information

 

If you have any questions relating to this statement they can be emailed to [email protected] or sent by post to the Compliance Department, Ground Floor, 2 London Square, Cross Lanes, Guildford, England, GU1 1UN.

 

 

7. Statement of Approval

 

This statement has been approved by the Board of Directors for the financial year ending 31 December 2023.

 

This statement will be reviewed and updated on an annual basis.