Modern Slavery and Human Trafficking Statement

December 2024

This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015. It sets out the steps AFS Group Holdings Limited has taken during the financial year ending December 2024 to prevent modern slavery and human trafficking within our business operations and supply chains.

1. Our Business

AFS Group Holdings Limited is the holding company for AFS Compliance limited (an FCA authorised Principal firm), Asset Finance Solutions (UK) Limited (an Asset Finance Broker Network) and Synergy Commercial Finance Limited (a Commercial Finance Broker Network), providing finance solutions to businesses and individuals across the UK. We operate exclusively in the financial services sector, arranging finance through a network of lenders and supporting clients through appointed representatives (ARs).

While our business does not involve manufacturing or direct use of high-risk supply chains, we recognise our responsibility to ensure that slavery and human trafficking are not present in any aspect of our operations or the businesses we work with.

2. Our Commitment

We have a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically and with integrity in all business dealings, and to implementing effective systems and controls to ensure modern slavery is not taking place in:

• Our own operations;
• Our AR network;
• Our supplier relationships;
• The transactions and financing arrangements we facilitate.

3. Risk Areas

As a financial services intermediary, our direct exposure is low. However, we have identified potential risks in:

• Suppliers: IT providers, professional advisers, facilities management, and contractors.
• Clients & Transactions: Businesses in high-risk sectors (e.g. logistics, construction, manufacturing, agriculture).
• Recruitment: Use of temporary or agency staff, where vulnerable workers may be at risk of exploitation.

4. Policies and Procedures

We maintain a dedicated Modern Slavery and Human Trafficking Policy, approved by the Board, which sets out our governance, commitments, and reporting mechanisms. Key measures include:

• Mandatory compliance clauses in supplier and AR contracts.
• Supplier declarations confirming adherence to modern slavery legislation.
• Enhanced due diligence checks for higher-risk industries and overseas connections.
• A confidential whistleblowing channel for staff, ARs, and suppliers to raise concerns without fear of reprisal.

5. Due Diligence

To manage identified risks, we:

• Screen new suppliers and ARs for compliance with modern slavery legislation.
• Carry out periodic reviews of our supplier base.
• Require ARs to adopt and certify compliance with our standards.
• Escalate any red flags to the Compliance Director and, where necessary, refuse to proceed with transactions.

6. Training and Awareness

We provide training to staff and ARs to help them:

• Understand the risks of modern slavery in financial services and supply chains.
• Recognise red flags during client onboarding and supplier engagement.
• Report any concerns through the correct channels.

Refresher training is delivered annually, with enhanced sessions for compliance and client-facing staff.

7. Effectiveness and Monitoring

We measure the effectiveness of our actions through:

• Percentage of staff and ARs trained each year.
• Supplier/AR compliance certification rates.
• Incidents raised and actions taken.
• Annual policy and risk review at Board level.

Where concerns are raised, we investigate thoroughly and take corrective action, including termination of supplier or AR relationships if breaches are identified.

8. Future Plans

During the next financial year, we will:

• Enhance supplier due diligence with a risk-based audit programme.
• Improve AR monitoring by embedding modern slavery checks into compliance audits.
• Expand training with case studies and scenario-based modules.
• Continue to monitor developments in legislation and best practice.