Modern Slavery and Human Trafficking Statement
1. Introduction
This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 and sets out the steps that Trussle Lab Ltd, trading as Better.co.uk, has taken, and continues to take, to prevent modern slavery and human trafficking within our business and supply chains.
We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place in any part of our own business or our supply chains. Where we work with independent third parties who are not part of our supply chains, we set expectations of them and take the steps described in this statement. Our policies and procedures relating to the Modern Slavery Act are in line with our culture and values, and with those of the OneDome group of which we are part.
2. Our Business
Trussle Lab Ltd is a UK-based financial technology company providing mortgage, protection and secured loan advice to consumers through the Better.co.uk brand and digital platform. We are authorised and regulated by the Financial Conduct Authority (firm reference number 924229) and are registered in England and Wales (company number 09459339).
We connect customers with lenders, insurers and related professional service providers, and give regulated advice through our own advisers. Our operations are largely office-based and remote, and are supported by a team of employees and self-employed contractors. Trussle Lab Ltd is a subsidiary of OneDome Ltd and operates within the group's governance framework.
3. Our Supply Chains and Ecosystem
Our direct business to business supply chains include:
Cloud hosting and infrastructure providers
Software and data service providers
Professional services (legal, accounting, recruitment)
Serviced office premises. Our Cardiff premises are provided on a serviced basis, so cleaning, maintenance and security are procured by our serviced-office provider rather than by us directly. We treat that provider as part of our supply chain and the labour-intensive services it procures as a tier below it
In addition, our service enables customers to access a broader network of independent third-party product and service providers ("Providers") across the financial and legal services sector, including lenders, insurers, conveyancers, surveyors and introducers. These Providers are independent businesses and are not part of our supply chain for the purposes of section 54. We nonetheless set expectations of the Providers we work with, as described in sections 4 and 5, and will act where we identify a concern.
4. Our Corporate Governance and Policies
We are committed to preventing modern slavery and human trafficking in both our direct operations and, where possible, within our ecosystem.
OneDome Ltd has adopted the QCA Corporate Governance Code, which considers, amongst other things, the key stakeholders with whom the group engages and their alignment with its strategic goals and code of ethics. Principle 4 of the Code specifically locates responsibility for oversight of the group's approach to social governance issues with the Board. Those responsibilities include identifying key internal and external stakeholders, promoting effective engagement, and ensuring that practices towards employees (direct and indirect) as well as employee conduct within the business are consistent with the group's values. Trussle Lab Ltd operates within that framework, and its own Board is accountable for applying it in our business.
To enable stakeholders to raise concerns, appropriate policies are in place to ensure that such matters are considered in confidence and that appropriate actions may be taken.
These policies include:
Employee Code of Conduct, setting out expected ethical standards of behaviour as an employee.
Recruitment processes in line with local employment laws.
Employment policies that reflect market appropriate compensation, protect our employees from unfair treatment and promote a fair and inclusive workplace.
Board Terms of Reference.
Supplier and Partner Due Diligence Policy.
Whistleblowing Policy, allowing concerns to be raised confidentially.
We also expect Providers we work with to comply with all applicable laws and to operate in a manner consistent with these principles.
5. Due Diligence and Ecosystem Controls
As an organisation, we take a proportionate and risk-based approach to due diligence. Measures include:
Onboarding checks for Providers, which may include identity verification and basic business information.
Requiring acceptance of business terms that include compliance with applicable laws, including those relating to modern slavery.
Working with reputable suppliers and service providers in our direct supply chain.
Reviewing higher-risk categories of Provider where appropriate.
We recognise that our ability to directly control independent providers is limited; however, we aim to use our corporate governance framework to promote responsible practices.
6. Risk Assessment and Management
We recognise that modern slavery risks may arise in:
Labour-intensive services (e.g. cleaning, maintenance, security).
Providers operating in higher-risk geographies or sectors.
Informal or subcontracted labour arrangements.
We assess risk based on the nature of the services provided and the location in which they are performed, and prioritise attention on higher-risk categories. The majority of our supply chain is UK based and within the professional services sector, which we assess as lower risk. That assessment does not extend to every part of our operations, and the locations described below are assessed separately. The Executive Team and Board remain committed to ongoing risk assessment as part of their day-to-day business responsibilities. Where concerns are identified, we may take steps including engagement, suspension, or termination of the engagement or partnership arrangement.
Our business largely consists of professionally qualified people. They are either employed directly by Trussle Lab Ltd, or engaged through UK regulated firms with which we have exclusive distribution arrangements. Our arrangements with those firms require compliance with applicable employment law and with law relating to modern slavery.
We are supported by colleagues based outside the United Kingdom. The OneDome group has people in Ukraine, Germany and South Africa. In Ukraine, software engineering support is provided by a combination of group employees and individual contractors. In Germany and South Africa, the group’s people are engaged as employees. We assess each location separately rather than applying a single conclusion to all non-UK activity.
We assess Germany as lower risk. We assess Ukraine and South Africa as carrying an elevated risk of modern slavery and human trafficking, and we do not treat that risk as immaterial because the work is professional or because the people concerned sit within our own group. In Ukraine, we recognise that conditions arising from the conflict, including restrictions on leaving the country, can place individuals in a position of greater vulnerability even where our own conduct is sound, and that contractor arrangements carry a further risk that work is sub-contracted or performed through arrangements we cannot see. In South Africa, we recognise that risk concentrates in third-party labour broking arrangements. The steps we are taking in relation to both locations are set out in section 10.
7. Reporting and Whistleblowing
We encourage employees and other stakeholders to report any concerns related to unethical practices, including modern slavery. Reports can be made through our whistleblowing channels and will be treated seriously and confidentially.
8. Training and Awarenes
Given our size, formal training is limited; however:
Relevant staff are made aware of modern slavery risks, particularly in relation to third-party provider activity.
Management maintains awareness of obligations under the Modern Slavery Act 2015.
The Board of Directors are aware of their responsibilities for the oversight, maintenance and regular review of robust corporate governance policies and practices, as set out in the QCA Corporate Governance Code and the OneDome Board Terms of Reference.
We intend to expand training and guidance as the business grows.
9. Effectiveness and Monitoring
We monitor our effectiveness through:
Ongoing review of stakeholder and employee feedback.
Monitoring and investigation of any reported concerns.
Periodic review of policies and business terms and conditions.
We have not identified any instances of modern slavery within our direct operations. We remain vigilant regarding risks within our supply chain and wider ecosystem.
10. Future Steps
We are committed to continuous improvement and will:
Enhance onboarding and verification processes for new suppliers, partners and service providers.
Complete and document a review of the engagement, pay and working-time arrangements for the group’s people in Ukraine and South Africa, covering both employees and contractors, and report the outcome in next year’s statement. For contractor arrangements, that review will address whether work is sub-contracted or performed through any intermediary or labour broker.
Obtain and review the modern slavery statement of our serviced-office provider, and record the outcome of that review.
Introduce clearer standards and guidance for providers we work with.
Explore additional mechanisms for risk-based monitoring of higher-risk service categories.
Provide additional internal training and awareness.
11. Approval
This statement is approved by the Board of Directors of Trussle Lab Ltd and signed by a director, and will be reviewed annually. It is published on Better.co.uk, with a link in a prominent place on the home page, and is submitted to the Government’s modern slavery statement registry.
