Modern Slavery and Human Trafficking Statement 2023
This statement outlines the steps that Bank of Africa United Kingdom Plc ( the “Bank”) is undertaking to ensure that modern slavery or human trafficking is not occurring within our business or supply chain.
Bank of Africa United Kingdom Plc has a zero-tolerance approach to modern slavery. We are committed to acting ethically, 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.
Post - COVID-19 Pandemic
Bank of Africa United Kingdom Plc has continued to monitor the risk of modern slavery in its operations and supply chains. Whilst travel and entertainment are considered high-risk sectors in our supply chain concerning modern slavery, activity in the area of travel and entertainment has been minimal when Covid related restrictions were in place. Day-to-day activity has since adjusted to a new reality of hybrid working arrangements with travel and entertainment picking up pace significantly since the lifting of restrictions. However, the activity in this area remains still below what was seen pre-Covid. Centralised processes are in place to ensure that any action in this area is monitored and that, where appropriate, any activity is booked using the approved providers.
Our customers and counterparties
How we do business is as important as what we do. We want to build trust with our Bank of Africa United Kingdom Plc stakeholders. Part of that trust stems from our duty of confidentiality to our clients and customers, subject only to regulatory or legal disclosure obligations.
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 the illicit use of the financial system by criminals. We must be alert to the presence and activities of those who would otherwise abuse our banking facilities. Our financial crime risk management framework arrangements ensures that the Bank’s exposure to these elements are readily assessed and controlled.
We recognise the need to manage social and environmental aspects in our business dealings. Accordingly, we apply human rights and modern slavery considerations in our due diligence processes relating to our lending and financing activities. We shall continue to enhance and strengthen these processes not only at the Bank’s level but also at the group level.
The commitments set out in this statement apply to all who work for the Bank of Africa United Kingdom Plc, regardless of where they are located. In our business dealings, we strive to raise awareness of human rights and act as an example of good practice through our 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 free from discrimination and harassment.
We are committed to operating by the International Bill of Human Rights and take into account the United Nations 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 the rights and dignity of all employees as well as our whistleblowing policy which encourages staff to report any concerns about illegal activity. In addition, 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 various channels, including written contracts, policies and staff handbooks. In addition, staff receive training on various human rights-related issues, including but not limited to diversity, money laundering, supplier management, terrorism financing, bribery and corruption.
Our Supply Chains / Outsourcing
The most considerable 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, 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 and child labour, 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 an obligation to comply with the Code of Conduct for Suppliers in contracts with 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 adequate 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. Therefore, as well as seeking to identify modern slavery and human trafficking in our operations and supply chains, the Bank has a responsibility to deter, detect and prevent illicit use of the financial system by criminals seeking to conceal themselves in many guises.
Bank of Africa United Kingdom Plc sees the risk of directly employing victims of modern slavery as low. However, we are committed to ensuring our supply chain is free from these practices. Of our leading 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 uses reputable recruitment agencies who provide the necessary assurances and checks on candidates. Bank of Africa United Kingdom Plc further undertakes reviews, including document checks, ensuring all job candidates are aged 16 or over. We pay our staff appropriate market salaries, rewards, and 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 also provide 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 approved by the Board of Directors annually.