Modern Slavery Policy

1.1   Policy ownership/oversight

This policy is owned by the General Counsel and MLRO. This policy will be approved by the OpCo and the RemCo and will be reviewed annually.

1.2   Policy scope

All business areas and all colleagues are in scope for this Policy, including contractors, agency workers, consultants, temporary staff and all third-party suppliers.

The Modern Slavery Act (MSA) 2015 aims to prevent modern slavery and human trafficking, as well as to protect and support victims. It encompasses four key areas; slavery, servitude, forced or compulsory labour and human trafficking.

• Slavery – Exercising powers of ownership over a person
• Servitude – The obligation to provide services is imposed by the use of coercion
• Forced or compulsory labour – Work or services are exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily
• Human trafficking – Arranging or facilitating the travel of another person with a view to their exploitation

Modern slavery is a complex and multi-faceted crime and tackling it requires all individuals within the organisation to be aware of it and to play their part.

As an equal opportunities employer, we’re committed to creating and ensuring a non- discriminatory and respectful working environment. We want all our staff to feel confident that they can expose wrongdoing without any risk to themselves.

Due to the nature of our business, Recognise Bank is considered a low-risk firm. Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and are subject to disclosure and barring, credit checks, and referencing which significantly reduces the risk of modern slavery.

However, there remains an element of risk when considering any third-party suppliers or outsourced activities including but not limited to cleaning, waste management, property maintenance, etc.

To mitigate this risk we do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.

The Company, our managers and our colleagues have a number of responsibilities to ensure the safeguarding of our colleagues and that everyone is treated fairly and with dignity, as outlined below.

Everyone at Recognise Bank must observe this Policy and be aware that ‘turning a blind eye’ is unacceptable. The Company will:

• Maintain clear policies and procedures preventing exploitation and human trafficking, protecting our workforce and reputation
• Have a clear recruitment policy
• Ensure our key suppliers are clear on our expectations regarding the Modern Slavery Act
• Make sure the appropriate checks are conducted on all employees, recruitment agencies and third-party suppliers
• Ensure we have open and transparent grievance and whistleblowing processes in place for all colleagues.
• Seek to raise awareness so that our colleagues know what we are doing to promote their welfare
• Make a clear statement that we take our responsibilities to our colleagues and our clients seriously (see Anti-slavery statement)

Managers will:

• Listen and be approachable to colleagues wanting to raise concerns
• Respond appropriately if they are told something that might indicate a colleague is in an exploitative situation
• Remain alert to potential indicators of slavery (see Identifying Slavery below)
• Raise awareness, ensuring all colleagues and third-party suppliers are provided with a copy of this policy and are aware of their responsibilities
• Use their experience and professional judgement to gauge situations

All Colleagues will:

• Keep your eyes and ears If you suspect someone (a colleague or someone in our supply chain) is being controlled or forced by someone else to work or provide services, follow our reporting procedure (see Reporting Slavery)
• Follow our reporting procedure if a colleague tells you something you think might indicate they are or someone else is being exploited or ill-treated
• Tell us if you think there is more we can do to prevent people from being exploited.

5.1   Anti-Slavery Statement

We make a clear statement that we take our responsibilities to our colleagues, people working within our supply chain and our clients seriously, this is updated annually.

5.2   Supply Chains

We tell the companies we do business with, that we are not prepared to accept any form of exploitation. All relevant supplier contracts contain an anti-slavery clause. This clause prohibits suppliers and their employees from engaging in slavery or human trafficking.

We apply reasonable due diligence to risk assessing our supply chain and use the following mechanisms to do this:

• Supplier mapping initially performed on spend level and then industry sector to identify key vulnerabilities
• Risk Assessment of spend areas in relation to the supply chain and their propensity of historically proven risk
• Ensuring all suppliers fully support the aims of this policy, (including asking for copies of their Anti Modern Slavery Statement and Policies)
• Harmonizing those processes which are already mutually inclusive of the aims of this policy into the due diligence.

If any issues are identified then these are escalated to the senior stakeholders in the business, with all methods of remediation to be available (up to and including exiting the relationship with the supplier). Where modern slavery concerns are raised within our supply chain, the General Counsel will be notified immediately, and an initial assessment will commence within 5 working days. The General Counsel will ensure that appropriate stakeholders are accountable for investigating, addressing risks, and implementing remediation actions.

5.3   Recruitment

Using Agencies:

• Our Company policy is to only use reputable recruitment agencies that we have agreed terms with.
• We expect all recruitment agencies with whom we engage to fully comply with the Modern Anti-Slavery Act 2015; ensuring they are free from ethical ambiguities and are transparent, accountable and auditable.
• If the Company has reason to believe that any recruitment agency has failed to meet these standards, the General Counsel should be informed and any contracts with them will be terminat Concerns will be assessed in a similar manner as described in 5.2(d) and escalated to the ExCo when appropriate.

5.4   General Recruitment

• We always ensure all staff have a written contract of employment.
• We always ensure staff are legally able to work in the UK.
• We provide information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to.
• If, through our recruitment process, we suspect someone is being exploited, then HR will be informed and the HR department will follow our reporting procedures.

There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support.

However, the following key signs could indicate that someone may be a slavery or trafficking victim:

• The person is not in possession of their own passport, identification or travel documents.
• The person is acting as though they are being instructed or coached by someone else.
• They allow others to speak for them when spoken to directly.
• They are dropped off and collected from work.
• The person is withdrawn or they appear frightened.
• The person does not seem to be able to contact friends or family freely.
• The person has limited social interaction or contact with people outside their immediate environment.

This list is not exhaustive.

Remember, a person may display a number of the trafficking indicators set out above but they may not necessarily be a victim of slavery or trafficking. Often you will build up a picture of the person’s circumstances which may indicate something is not quite right. If you have a suspicion, report it to the HR Department who will follow our reporting procedures.

Talking to someone about your concerns may stop someone else from being exploited or abused.

If you think that someone is in immediate danger, dial 999.

Otherwise, you should raise your concerns via one of the following internal channels:

• Discuss with the General Counsel who will decide an appropriate course of action which may include contacting the Police or the Gangmasters and Labour Abuse Authority (GLAA)
• Report using our confidential and anonymous whistleblowing channel
• Speak directly to HR if you prefer to raise it with someone other than your line manager

All concerns raised internally will be assessed and an action plan will be assigned to accountable leads. The General Counsel will update ExCo on all allegations of modern slavery until resolution.

Not all victims may want to be helped and there may be instances where reporting a suspected trafficking case puts the potential victim at risk, so it is important that, in the absence of any immediate danger, you first raise concerns internally so that risks to the individual are carefully considered and managed.

We provide protection to colleagues who report concerns in good faith and will not tolerate any form of retaliation.

There is a requirement for all employees to comply with this policy and complete the annual mandatory training on preventing human trafficking.