Modern Slavery Statement

Our Company

TMG Limited is a financial services business based solely within the UK, which offers a range of financial products through its subsidiary companies, including credit score services, unsecured personal loans, credit card and mortgages as a broker, personal accounts and debt advice and insolvency services. The subsidiaries include:

  • Financial Wellness Group Limited
  • Freeman Jones Limited
  • Gregory Pennington Limited
  • Intelligent Lending Limited (trading as Ocean Finance, Ocean and CredAbility)
  • Think Money Limited

This statement is on behalf of TMG Limited and its subsidiaries.

Our Policies

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business. Our policies, specifically: Anti-slavery and Human Trafficking Policy, Whistleblowing Policy, Conflicts of Interest Policy and Supplier Management Policy reflect the Group’s values and in turn our commitment to act ethically and with integrity in our business relationships.

Our Supply Chains

As we are engaged in the provision of financial services our supply chain is relatively straightforward. We remain focused to ensure that all our goods and services are supplied from compliant providers to run our business effectively and ethically.

Our Due Diligence Practices

As part of our initiative to identify and mitigate risk we perform due diligence on all new suppliers aimed at assessing their business across a number of areas including information security, legal and regulatory compliance and financial conduct. This due diligence exercise includes specific questioning on modern slavery and human trafficking.

In addition to the due diligence performed on new suppliers, existing suppliers are required to complete a self-assessment questionnaire annually which further addresses compliance with the requirements of the Modern Slavery Act 2015 (Act).

Supplier Adherence to our Values

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors continue to comply with our values we have in place a supply chain compliance programme which is monitored by our compliance team, and involves input from the following departments: Legal, Compliance, Audit and Procurement.

TMG only trades with suppliers who comply with these policies.

Risk Assessment

Due to the nature of the services we provide, we consider the inherent risk of modern slavery and human trafficking occurring in our business to be low. However, we take our responsibility to identify and effectively respond to any incidents of modern slavery and human trafficking very seriously and will continue to review our policies and procedures and make enhancements where we deem necessary.

Key Performance Indicators

We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavey and human trafficking is not taking place in any part of our business or supply chains:

  • Regular due diligence – the number of supplier reviews, subject to a risk based approach
  • Training and education – the number of individuals that training is provided to


We ensure that all of our employees and our supplier chains have a high level of understanding of the risks of modern slavery and human trafficking, and are made aware of the provisions, requirements and importance of the Act.

All training of the Act and the wider issues of slavery and human trafficking is completed through our online portal.

Further Actions

Following a review of the effectiveness of the steps we have taken so far to ensure that here is no slavery or human trafficking in our supply chains, we intend to take the following further steps to combat slavery and human trafficking:

  • Continue to strengthen our reviews of our key suppliers and partners to include compliance with the Act
  • Enhance training and policies to clearly articulate the minimum standards of the Act, and to implement and embed across the Group and its subsidiaries.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending 31st January 2023.

Stephen Stylianou, CEO

July 2023