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.
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
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.
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.
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
- 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