Modern Slavery and Human Trafficking Statement

1. Introduction and Commitment

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015. It sets out the steps that Portman Finance Group Limited (“the Company”) has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or our supply chains.
As a broker and specialist provider of asset finance and working capital solutions, we recognise our responsibility to operate with integrity. We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with transparency in all our business dealings.

2. Our Business and Structure

We operate as a hybrid financial services group, acting as both a:
Credit Broker: Introducing clients to a diverse panel of institutional and specialist funders.
Direct Lender: Providing working capital and asset-backed facilities to corporate SMEs.
Our operations are based in the United Kingdom, [exclusively] serving the UK market. Our supply chains consist of professional service providers (legal, audit and IT), software-as-a-service (SaaS) platforms and the equipment suppliers (dealerships and manufacturers) involved in the asset finance transactions we fund or broker.

3. Risk Assessment and Due Diligence

Given the nature of financial services, we consider the risk of modern slavery within our own immediate workforce to be low. However, we recognise potential risks in two external areas:
A. Supply Chain (Procurement)
We categorise our suppliers based on risk. While our professional service providers are low risk, we exercise increased vigilance regarding “indirect” supply chains, such as cleaning and office maintenance services.
B. Transactional Risk (Clients and Assets)
As a lender and broker, our primary risk lies in the sectors we finance. We perform enhanced due diligence on high-risk industries


Due Diligence Processes:
KYC and KYB: We perform rigorous “Know Your Customer/Business” checks on all clients and beneficial owners.
Asset Verification: For asset finance, we verify the origin of equipment and the legitimacy of the supplying dealer.
Funding Panel: We review the Modern Slavery Statements of our funding partners to ensure alignment of values.

4. Relevant Policies

We operate the following policies that assist in the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:
Modern Slavery and Human Trafficking Policy: Our primary internal governing document.
Whistleblowing Policy: We encourage all employees, customers and business partners to report any concerns related to the direct activities or the supply chains of, the Company.
Anti-Money Laundering (AML) Policy: Our AML framework includes “Red Flag” indicators that may signal human trafficking or exploitation (e.g., unusual wage payments or restricted access to bank accounts).
Anti-Bribery and Corruption: Many of the conditions that lead to or influence the existence of modern slavery may not exist without corrupt activity.
Vulnerable Customers: Those who are the victims of modern slavery will by their situation be vulnerable and have the same or similar “Red Flags” to those detailed in the Vulnerable Customer policy.

5. Training and Awareness

To ensure a high level of understanding of the risks of modern slavery in our supply chains and our business, we provide mandatory annual training to all staff. This training covers:
How to identify the signs of slavery and human trafficking.
What initial steps should be taken if modern slavery is suspected.
How to escalate concerns to the relevant department or the Board.

6. Key Performance Indicators (KPIs)

We use the following KPIs to measure how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains:
Completion Rate: 100% completion of modern slavery training by staff.
Introducer Screening: Reviewing 100% of new material introducers against our ethical standards.
Incident Reporting: Maintaining a record of all investigations into modern slavery).

7. Board Approval

This statement has been approved by the Board of Directors of Portman Finance Group Limited, who will review annually and update it when required.

Alex Read Signature


Alex Read
Chief Executive Officer
January 2026