Bank of Ireland Group
Modern Slavery & Human Trafficking Statement
We strive to ensure that there is no modern slavery or human trafficking in our supply chain or in any part of our business. This objective is an integral part of our policies and our approach to human rights.
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 with respect to the financial year ending 31 December 2021 and sets out the steps Bank of Ireland Group has taken to prevent the occurrence of modern slavery and human trafficking in our supply chain or in any of our business operations in the United Kingdom and elsewhere.
Bank of Ireland Group (the “Group”) is one of the largest financial services groups in Ireland with total assets of €155 billion at 31 December 2021. The Group provides a broad range of banking and other financial services to retail and business customers in Ireland, the United Kingdom and internationally. These services include current account and deposit services, overdraft facilities, term loans, mortgages, business and corporate lending, international asset financing, leasing, instalment credit, invoice discounting, foreign exchange facilities, interest and exchange rate hedging investments, life assurance, motor finance, pension and protection products. All of these services are provided by the Group in Ireland with selected services being offered in the United Kingdom and internationally. In the United Kingdom, a selection of financial services are provided by Bank of Ireland (UK) plc, a separately authorized and regulated banking and financial services business, NIIB Group Limited, an asset finance and consumer lending group and Marshall Leasing Limited, a car leasing group and The Governor and Company of the Bank of Ireland, UK Branch. You can find out more about the Group’s trading divisions in all jurisdictions, and a list of its products and services here. This statement has been adopted by the following companies within the Group:
- Bank of Ireland (UK) plc
- NIIB Group Limited
- Marshall Leasing Limited
- The Governor and Company of the Bank of Ireland, UK Branch
The Group operates a number of policies which reflect our objective to acting ethically and in line with our legal and regulatory obligations regarding our employees, customers and our business relationships.
- The Group Code of Conduct is the standard that we set ourselves for what we say and do in our relationships with our customers, suppliers, colleagues, shareholders, regulators, government bodies and other parties. The Group Code of Conduct represents our approach to the standards we expect from each other, and it prescribes a set of behaviours expected of all employees of the Group, wherever they work. We organise these standards under four principles with clear lines of individual responsibility:
- Customers – we treat customers fairly;
- Conduct – we act with integrity in our dealings;
- Colleagues – we are respectful to each other and value the contribution of others;
- Compliance – we comply with the Group Code of Conduct, our policies and any applicable legal and regulatory obligations.
- The Group Speak Up Policy details the procedures our employees should follow if they have concerns about any wrongdoing, unlawful conduct, bribery, financial malpractice, dangers to the public or the environment, or possible fraud or other risks to the Group. This includes concerns with respect to our suppliers or practices within our business or supply chain.
- The Group Recruitment Policy outlines our approach to recruiting employees for jurisdictions in which the Group operates. The principles of equality and diversity underpin our resourcing activity, seeking to ensure that our recruitment and selection processes are designed to support fairness and diversity in the workplace.
- Group Anti-Bribery and Corruption Policy applies to all employees and agents of the Group, and to all relevant suppliers of the Group and its subsidiaries, and to the Employees and agents of such suppliers, and sets out the rules regarding bribery and corruption.
- Group Anti-money Laundering Policy applies to all staff directors, agents and contractors of the Group and its subsidiaries and any providers of services to the Group under outsourcing arrangements and sets out policies and procedures to prevent the commission of financial crime and the movement of money which has derived from crime.
- Group Procurement Policy sets out the Group requirements for the effective procurement and management of goods and services from third party suppliers while ensuring that procurement best practices are consistently followed across the Group.
- Group Sourcing Risk Policy sets out the Group requirements for the effective management of sourcing related operational risks within the Group.
Our Supply Chain
As the Group is not in an industry with a high risk of modern slavery or human trafficking, a risk-based approach has been adopted. This means that we continually review our supply chain (which predominantly consists of goods and services purchased from third party suppliers to assist us in the provision of financial services to our customers) across industries that carry a high risk of modern slavery or human trafficking.
- In conducting appropriate due diligence, the Group assesses its suppliers across a number of key risk areas, at the on-boarding stage for all suppliers and annually thereafter for suppliers providing services of high criticality and dependency to the Group. We have also introduced a procurement platform that supports supplier due diligence intended to identify risks of modern slavery and human trafficking.
- The Group publishes a Code of Supplier Responsibility that sets out our expectations of our suppliers, and it seeks assurances (where appropriate) from our suppliers that they are complying with applicable laws and regulations including laws relating to minimum wages, working conditions, overtime, child labour and other applicable labour and environmental laws. This allows us to select suppliers to work with us who adhere to appropriate standards.
- Detailed financial analysis and assessment of suppliers, reputation and experience is carried out. We also seek to identify if our suppliers operate a vendor management programme and carry out due diligence on their own suppliers to ensure that appropriate standards are being passed through the supply chain.
- Our suppliers are required to notify us of a breach of applicable laws or regulations and outline their practices and procedures to ensure they do not engage in modern slavery or human trafficking (including within their own supply chain). This includes monitoring the content of modern slavery and human trafficking statements published by our suppliers and completing additional assurance activity when we visit our supplier sites.
Training and Awareness
The Group is focused on raising awareness of the policies listed above with colleagues across the organisation. This includes the provision of mandatory training for employees on the Group Code of Conduct and Speak Up Policy each year.
Our managers also receive further support that includes training and line management guidance to ensure consistency of our recruitment processes, management of suppliers, fair treatment at work, and inclusion and diversity.
Court of Directors Approval
Responsibility for ensuring that the Group has appropriate policies in place to meet our statutory obligations rests with the Court of Directors which has delegated the responsibility for approval of this Statement to the Nomination and Governance Committee.
This Modern Slavery & Human Trafficking Statement has been approved by the Nomination and Governance Committee on 27 July 2022 on behalf of the Bank of Ireland Group and will be reviewed annually.
Group Chief Executive Officer