This statement is made pursuant to section 54, Part 6 of the Modern Slavery Act 2015 (the “Act”) and sets out the steps that BCMGlobal has taken to reduce, as far as possible, the risk that slavery and human trafficking takes place in any parts of its business or supply chains.

This statement was approved by the Board of Directors on 1st May 2024.

BCMGlobal has a zero-tolerance approach to slavery and human trafficking and is making this statement to show our commitment to ethical trading principles and to set out the steps we are taking to tackle modern slavery and human trafficking in our business and in our supply chains. 

Our Business

BCMGlobal Mortgage Services provides loan administration services as to loan assets secured by residential and commercial real estate located in the United Kingdom and is part of the wider BCMGlobal business.

BCMGlobal provides banking and credit management services and is a leading European independent loan and asset management service provider supporting clients in both Primary Markets (new originators of loans) and Secondary Markets (purchasers of existing loan portfolios). BCMGlobal has multijurisdictional expertise with operations in Ireland, the UK, the Netherlands and Italy, supporting loans for commercial, investment purposes and mortgages across the loan lifecycle, from origination to redemption. BCMGlobal is part of the LC Financial Holdings Ltd (“LCFH”).

LCFH also operates various debt purchase, loan administration and servicing, loan servicing software and legal services businesses in the UK, Ireland, France, Spain, Portugal, Germany, Italy, Romania and Poland.

Our People and Policies

Our success depends not only on our technical ability, but also on our employees and wider workforce acting ethically. We are committed to complying with the applicable financial regulations and conduct rules that are prevalent in our industry, creating a fair and transparent working environment within our business. This is demonstrated by our Whistleblowing policy and the values set out in our employee policies. 

Our Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our employees. Completion of this training is monitored by our management team.

Our Supply Chains

We expect the same of our material suppliers and focus on developing relationships with these suppliers based on transparency. Although our material suppliers operate independently and in different industries, we recognise that their actions can impact our reputation. As such, we strive through our procurement due diligence processes and third-party supplier policies to select suppliers that share our values and demonstrate a commitment to the highest professional standards and ethical conduct in their business dealings.

The nature of our business is such that our material supply chain consists primarily of professional services suppliers, such as solicitors, field agents, storage facilities, office supplies and technology providers, substantially all of whom are based in or operating from the UK or the European Union. Consequently, we consider our supply chain to be low risk with regards to such relationships and ‘modern slavery’ and do not consider any further action to be necessary to mitigate the risk of “modern slavery” in the supply chain. 

We are, however, committed to taking all appropriate steps to mitigate the risk of slavery or human trafficking taking place in our supply chain. We periodically review our procurement and supply chain management procedures with a view to further reinforcing this commitment. 

Our effectiveness in combating slavery and human trafficking

We have not identified any areas requiring immediate action with regard to supplier relationships, beyond our regular procurement due diligence processes and our internal third-party supplier policies. We are, however, committed to taking all appropriate steps to mitigate the risk of modern slavery or human trafficking taking place in our supply chain. We are committed to undertaking regular reviews of our procurement and supply chain management procedures to ensure that we are doing everything we can to identify, mitigate and eliminate the risk.