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Modern Slavery Statement

Modern Slavery and Human Trafficking Statement 2021

This statement sets out the steps that Bank of Africa United Kingdom plc (or the “Bank”) is undertaking to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Bank of Africa United Kingdom plc has a zero-tolerance approach to any form of modern slavery. We are committed to acting in an ethical manner, with integrity and transparency in all business dealings.

We are committed to creating effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain and impose those same high standards on our contractors, suppliers and other business partners.

Impact of the COVID-19 Pandemic

Bank of Africa United Kingdom plc has continued to monitor the risk of modern slavery in its operations and supply chains, especially during these extraordinary times. We consider travel and entertainment as high-risk sectors in our supply chain in relation to modern slavery, but with virtually no activity in this area due to the COVID-19 pandemic restrictions, this risk has reduced significantly during 2020-2021.

Our customers and counterparties

How we do business is as important as what we do. We want to build trust with our stakeholders at Bank of Africa United Kingdom plc . Part of that trust stems from our duty of confidentiality to our clients and customers, subject only to regulatory or legal obligations of disclosure.

Slavery and human trafficking are crimes. The criminals responsible will seek to hide the proceeds of their crimes in the financial system to legitimise them – effectively, money laundering – and banks have a responsibility to deter, detect and prevent illicit use of the financial system by criminals. We must be alert to the presence and activities of those who would otherwise abuse the banking facilities that we offer.

We recognise the need to manage social and environmental aspects in our business dealings. We apply human rights and modern slavery considerations in our due diligence processes relating to our lending and financing activities and shall continue to enhance and strengthen these processes.

The commitments and policies referred to in this statement apply to all who work for Bank of Africa United Kingdom plc. We seek, within our business dealings, to raise awareness of human rights and act as an example of good practice through our own business conduct.

Within Bank of Africa United Kingdom plc

Bank of Africa United Kingdom plc applies human rights considerations directly as they affect all employees; treating all employees with dignity and respect in an environment that is free from discrimination and harassment.

We are committed to operating in accordance with the International Bill of Human Rights, and take into account the UN Guiding Principles on Business and Human Rights and other internationally accepted standards, including the International Labour Organisation Declaration on Fundamental Principles and Rights at Work.

These commitments are reflected in our policies which set the standard of expected business behaviour for all employees and include our staff handbook which aims to foster a workplace environment that is fair, open and respectful and one that promotes and protects rights and dignity of all employees as well as our whistleblowing policy which encourages staff to report any concerns about illegal activity. We keep our policies under constant review and where required, strengthen them to further embed our commitment to combatting modern slavery and other related issues.

Bank of Africa United Kingdom plc staff are made aware of their rights through a variety of channels, including written contracts and staff handbooks. Staff receive training on a variety of human rights related issues, including but not limited to diversity, money laundering, supplier management, terrorism financing, bribery and corruption.

Our Supply Chains / Outsourcing

The biggest risk of directly encountering modern slavery for Bank of Africa United Kingdom plc lies where the Bank does not have direct management control. In particular this may include suppliers who provide support staff in, for example, catering, cleaning or security posts.

Bank of Africa United Kingdom plc has a Code of Conduct for Suppliers. As articulated in this Code, Bank of Africa United Kingdom plc requires suppliers to respect the human rights of their employees and the communities in which they operate as well as to comply with all relevant legislation, regulations and directives, in the countries and communities in which they operate. Suppliers must prohibit the use of forced labour and child labour and respect labour rights including non-discrimination and the right to freedom of association, and give workers, whether local or migrant, the right and the ability to leave employment when they choose, to the extent possible under local law.

Whenever possible, Bank of Africa United Kingdom plc will include in contracts with suppliers an obligation to comply with the Code of Conduct for Suppliers.

Bank of Africa United Kingdom plc aims to start a more in-depth risk assessment of its key suppliers and develop tailored management information to allow for Bank of Africa United Kingdom plc to confirm the effectiveness of its policies and procedures.

Protecting the financial system

Bank of Africa United Kingdom plc is committed to maintaining effective financial crime controls. As stated above, slavery and human trafficking are crimes and those responsible will seek to hide the proceeds in the financial system to legitimise them – effectively, money laundering. As well as seeking to identity modern slavery and human trafficking in our own operations and supply chains, banks have a responsibility to deter, detect and prevent illicit use of the financial system by criminals who may be seeking to conceal themselves in many guises.

Bank of Africa United Kingdom plc see the risk of directly employing victims of modern slavery as low. However, we are committed to ensuring that our supply chain is free from these practices. Of our main suppliers, most do business in the UK or Europe, or offer low-risk products or services. Some suppliers are located in higher-risk countries or offer higher-risk services such as security, cleaning and catering.

Bank of Africa United Kingdom plc only make use of reputable recruitment agencies, who provide the necessary assurances and checks on candidates. Bank of Africa United Kingdom plc further undertakes checks including document checks, ensuring that all candidates are aged 16 or above. We pay our staff appropriate market salaries and rewards, plus other benefits including health and welfare options.

Training, awareness and development section on modern slavery is included in the Bank’s financial crime training programme, which is mandatory for all staff. We have also provided additional guidance to staff directly involved in procurement to help them reduce the risks of modern slavery in our business and supply chain.

Governance

Our Modern Slavery and Human Trafficking Statement and our Supplier Code of Conduct are updated and reported to the Board of Directors on an annual basis.