S.172 Statement | Evlo

Statement by the Directors in relation to Performance of their Statutory Duties in accordance with Section 172(1) Companies Act 2006 (the “2006 Act”)

Overview

In accordance with the 2006 Act, the Directors of the Company provide this statement describing how they had regard to the matters set out in Section 172(1)(a) – (f) of the 2006 Act when performing their duty to promote the success of the business for the benefit of its members as a whole, taking into consideration the interests of stakeholders in their decision-making.

The Company’s ultimate parent company has no employees or customers of its own, and whilst its main stakeholders are currently its shareholders and its subsidiaries, due to its level of oversight over the Company, the approach taken in considering the matters set out in Section 172(1) of the 2006 Act set out below is similar for all legal entities within the Group, including the Company.

The Company carries out regular assessments of its stakeholders to help inform its stakeholder engagement strategy, which includes taking into consideration stakeholder views in Board decision-making. The stakeholder engagement strategy further delegates the day-to-day management of stakeholder interests to certain members of executive management.

Section 172(1)(b): The interests of employees
Stakeholders: Employees

Evlo recognises that its people are key to enabling the achievement of strategic and business goals. The Directors are also mindful of the importance of aligning organisational culture to a strong purpose. The Company prioritised the assessment and development of its people throughout 2025 to align with the operating model.

The Company regularly engaged with its employees during 2025 (and continues to do so) through:

  • The regular in person contact afforded by Evlo’s face-to-face business model.
  • Regular one-to-one meetings between employees and line managers.
  • Monthly performance and development reviews.
  • Employee engagement and feedback surveys.
  • Company-wide ‘Town Hall’ meetings and leadership updates.
  • The issuance of regular internal communications through Evlo’s platform.
  • Learning and development programmes to support professional growth.
  • Mentoring and coaching initiatives.
  • Employee recognition and reward programmes.
  • Wellbeing initiatives and access to employee support surveys.
  • Social and team-building activities to strengthen workplace culture.
Section 172(1)(c): Business relationships with suppliers, customers and others
Stakeholders: Customers
Regulators
Investors, as represented by the ultimate parent company
Suppliers

Customers

At Evlo, customers are at the heart of the business model. The Directors are committed to setting high standards in every customer interaction and throughout the entire customer journey. The Company’s dedication extends beyond responsible and professional lending, and it actively works to raise awareness and combat financial exclusion.

In line with this commitment, Evlo launched a new forbearance support suite in August 2025 to provide improved short-term options for customers experiencing financial difficulty. During the financial year, the Company also onboarded an offshore partner to maximise its ability to engage with customers both earlier in the journey and across an extended set of hours. This partnership has increased the Business’ ability to service customer appetite, particularly amongst customers who are unable to contact us during normal office hours due to work or family commitments. Evlo also made strides to further promote the interests of its customers and improve the visibility of their loans in 2025 by increasing the number of UK Credit Reference Agencies (CRAs) it reports to from 2 to 4, including the 3 main CRAs.

Throughout 2025, the Directors maintained regular oversight of key customer-focused areas, including:

  • The Three Lines of Defence governance structure
  • Dedicated quality reviews, ensuring continuous learning from customer interactions across lending and collections
  • Second-line thematic reviews, assessing customer outcomes in lending, customer service, vulnerability, and financial difficulty
  • Customer feedback at the account level via Feefo and Trustpilot
  • Thematic customer feedback, gathered through direct engagement
  • Key service performance measures linked to customer experience
  • Complaints monitoring and root cause analysis to drive improvements
  • Credit risk trends to ensure responsible lending
  • Internal audit review oversight to maintain high standards

By maintaining a strong focus on customer outcomes, Evlo continues to evolve and enhance its approach to responsible lending, customer engagement, and financial inclusion.

Regulators

The Company is authorised and regulated by the FCA to sell loan related products and recognises the need to ensure the delivery of ‘good customer outcomes’ throughout the customer journey and lifecycle through the deployment of a robust business model and culture. This, in turn, supports the success of the Evlo business, and the alternative finance sector, in remaining viable to service the flow of affordable and appropriate financially inclusive lending.

On 31 July 2023, the FCA enacted its Consumer Duty rules to set higher and clearer standards for consumer protection. The Company completed and submitted its second annual Consumer Duty Attestation in July 2025, and the Directors are provided with sufficient and regular oversight of the Company’s position against the four Consumer Duty outcomes (product and servicing; customer understanding; price and value; and consumer support).

The Company also directly engaged with the FCA as needed throughout 2025 and supported the Consumer Credit Trade Association’s engagement with the regulator on an industry level.

Investors

The Company is an indirect subsidiary of Evlo Limited (formerly NSF Finco Limited) and the main investors in the Company are Evlo Limited’s secured lenders, ultimately represented by Clareant Lending Holdco Ltd (CLHL). The secured lenders have provided debt funding which allows the Company to operate and deliver long term success. The Directors, led by the Chair, foster a positive relationship with investors through regular reporting to the CLHL Board of Directors and engagement on the matters covered by internal governance mechanisms and procedures.

Suppliers

The Directors are mindful of the importance of positive supplier relationships and robust due diligence processes to ensure the business, and its third parties, operate responsibly. The Company strives to be a reliable customer with which other firms can and want to do business and maintains good performance payment practices to ensure suppliers continue to be paid in a timely manner. This is evidenced by the Company being recognised and achieving a Good Business Pays Fast Payer Award during 2025.

From a controls’ perspective, the Board, its sub-committee and executive management built upon the significant work undertaken in 2024 and continued to pay close attention to identifying and managing the potential risks associated with customer facing third parties throughout 2025.

The Company has also adopted a zero-tolerance approach to modern slavery and human trafficking in any part of its supply chain and recognises the responsibility of all its people to avoid any activity that may lead to, or suggest, a breach of this position.

Section 172(1)(d): Impact of business operations on community and the environment
Stakeholders: Local community

Environment

The Company is committed to supporting its employees to engage in volunteering and offers three charity days to each member of staff per year. Additionally, the implementation of an internal Charitable Donations and Activities Policy to support the making of both financial contributions by the Business and employees in completing voluntary work, has given Evlo a foundation for providing support for the immediate and future needs of people across the UK in a more coordinated manner.

From a commercial perspective, Evlo enables its customers to have opportunities that mainstream finance providers do not offer and is committed to lending and collecting responsibly, and in a financially inclusive manner.

The Directors continue to assess the Company’s impact on the environment as well as how climate change may create additional risks as well as opportunities for the business. Evlo carries out energy assessments under the Energy Savings Opportunities Scheme (ESOS) and reports under the Streamlined Energy and Carbon Reporting (SECR) scheme on an annual basis. Please see the Company’s SECR and environmental strategy within pages 13-19 of this report respectively for more information.

Section 172(1)(e): Maintaining a reputation for high standards of business conduct
Stakeholders: Employees

Regulators

The Company has implemented numerous measures to support its people in relation to meeting personal conduct expectations and maintaining high business standards more generally. These include the enactment and regular review of internal policies and procedures governing the following matters:

  • Whistleblowing.
  • Pre-employment checks.
  • Grievances.
  • Dignity at Work.
  • Code of Conduct.
  • Modern Slavery and Human Trafficking.
  • Fraud.
  • Anti-Bribery and Corruption.
  • Anti-Money Laundering and Counter Terrorism Financing.
Section 172(1)(f): The need to act fairly as between members of the company
Stakeholders: Investors/CLHL

The Company is a private limited company with a sole shareholder. However, details of how the Directors regards the interest of its ultimate parent company and relevant investors are provided within the commentary for Section 172(1)(c) of the 2006 Act.