Modern Slavery Act

Lendable Modern Slavery Statement 2023

Organisational structure and supply chains

Lendable Operations Ltd (“Lendable” or “we”) operates a consumer lending technology platform. The platform seeks to build a leading position in consumer finance. The principal activities of Lendable include credit analysis, data analytics, technology development, asset management, and customer service. We had 464 employees as of the 19th of June 2024.

Lendable Ltd is a wholly owned subsidiary of Lendable Operations Ltd and is the originator and servicer of consumer finance products offering personal loans, credit cards and car finance in the UK.

Zendable, Inc. (“Zendable”) is another wholly owned subsidiary of Lendable which is incorporated in Delaware. Zendable’s subsidiary, Zendable LLC, services personal loans that are provided by its partner bank, Cross River Bank.

Lendable works with approximately 235 third party suppliers. Our supply chain is principally made up of direct third party suppliers who supply us with products and/or services which, in turn, help us to deliver services to our customers and employees.

Due Diligence

Our due diligence procedures aim to:

identify and manage potential risks in our business and supply chains;
monitor potential risks in our business and supply chains; and
reduce the risk of slavery and human trafficking occurring in our business and supply chains.

As part of Lendable’s efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:

our supplier on-boarding due diligence process requires suppliers to confirm that they have policies in place to ensure their respective businesses and supply chains are slavery free;
we have appropriate procedures in place to establish that all prospective colleagues have the right to work legally in the UK, and we perform background checks as part of the recruitment process;
all prospective colleagues are required to provide proof to demonstrate their right to work in the UK;
all colleagues are encouraged to raise concerns relating to potential breaches of regulations (including by third party suppliers), policy requirements and/or other grievances with the firm’s senior management; and
we ensure our suppliers are aware of our policies and adhere to no less stringent standards.

Policies in relation to slavery and human trafficking

Our commitment to combating modern slavery and human trafficking is embedded into our policies. Our policies have been designed to take account of the requirements of the Modern Slavery Act 2015 (the “Act”), including:

whistleblowing procedures in place to allow employees to raise concerns about any aspect of Lendable’s business practices;
employment policies and procedures outlining our commitment to fulfil all of our obligations as an employer in line with relevant UK employment and equality law requirements and best practices; and
a robust Procurement Framework incorporating supplier on-boarding due diligence requirements relating to the Act.

Risk assessment and management

The firm’s governance structure operates to the end of ensuring the on-going identification, assessment, monitoring and management of risks including modern slavery related risks.

We carry out checks to ensure that our employees’ salaries are in line with the minimum wage requirements. We have also put in place processes through our Procurement Framework that aim to ensure we only work with appropriate suppliers who can meet the standards expected of them.

Lendable’s Finance team has processes in place that operate to ensure that payments and funds for services performed by suppliers in our supply chain reach their intended recipients.

The firm will continue to review and monitor the due diligence approach to manage supply-chain related risks and will provide appropriate training where required.

Training on modern slavery and trafficking

We provide on-going training to our employees to ensure competence in monitoring our adherence to the Modern Slavery Act 2015 and compliance with this statement.

Key Performance Indicators

Measure	Current Assessment	Future Action
Assessment of suppliers before they are on-boarded into our supply chain.	Lendable’s supplier Due Diligence Questionnaire includes questions specific to the Act.	Further develop the supplier risk assessment process to identify suppliers from high risk* countries. *The latest Global Slavery Index, produced by human rights group Walk Free, reveals the 10 countries with the highest prevalence of modern slavery are North Korea, Eritrea, Mauritania, Saudi Arabia, Türkiye, Tajikistan, United Arab Emirates, Russia, Afghanistan, and Kuwait. The Global Slavery Index is a national breakdown of the extent of modern slavery in 160 countries.
Ensure expectations for suppliers in relation to requirements under the Act are clearly communicated and contractually defined.	New contracts contain clauses which require compliance with requirements of the Act, allowing us to work collaboratively with our suppliers to ensure that this risk is sufficiently mitigated. The majority of our contracts also include audit rights to enable us to assess a supplier’s compliance with their contractual obligations. Legacy suppliers’ contracts will be enhanced to ensure levels of protection equivalent to those afforded under new contracts.	Continue ensuring that our contracts are robust and effective in managing this risk.
Periodic review of associated and related policies where Lendable’s commitment to combating modern slavery and human trafficking is embedded.	Policies are subject to review in line with the frequency outlined for the policy level.	Continuing review of our policies.

Measure

Current Assessment

Future Action

Assessment of suppliers before they are on-boarded into our supply chain.

Lendable’s supplier Due Diligence Questionnaire includes questions specific to the Act.

Further develop the supplier risk assessment process to identify suppliers from high risk* countries.

*The latest Global Slavery Index, produced by human rights group Walk Free, reveals the 10 countries with the highest prevalence of modern slavery are North Korea, Eritrea, Mauritania, Saudi Arabia, Türkiye, Tajikistan, United Arab Emirates, Russia, Afghanistan, and Kuwait. The Global Slavery Index is a national breakdown of the extent of modern slavery in 160 countries.

Ensure expectations for suppliers in relation to requirements under the Act are clearly communicated and contractually defined.

New contracts contain clauses which require compliance with requirements of the Act, allowing us to work collaboratively with our suppliers to ensure that this risk is sufficiently mitigated. The majority of our contracts also include audit rights to enable us to assess a supplier’s compliance with their contractual obligations.

Legacy suppliers’ contracts will be enhanced to ensure levels of protection equivalent to those afforded under new contracts.

Continue ensuring that our contracts are robust and effective in managing this risk.

Periodic review of associated and related policies where Lendable’s commitment to combating modern slavery and human trafficking is embedded.

Policies are subject to review in line with the frequency outlined for the policy level.

Continuing review of our policies.

Conclusion

We are committed to helping combat modern slavery and human trafficking within our business and supply chains. We have zero-tolerance towards slavery and want to ensure our supply chain complies with our values.

This statement is made in accordance with section 54(1) of the Act and constitutes Lendable’s modern slavery and human trafficking statement for the financial year ended 31 December 2023. The statement was approved by the Board of Directors of Lendable and signed on its behalf by:

Martin Kissinger

Chair of the Board of Directors of Lendable Operations Ltd