Slavery and Human Trafficking Statement
Introduction from the Chief Executive Officer:
OSB is listed on the London Stock exchange and is a member of the FTSE 250. We are incorporated in the UK and headquartered in Kent. OneSavings Bank group is made up of a family of specialist financial services brands and subsidiaries namely, Kent Reliance, Prestige Finance, InterBay Commercial, Interbay ML. Limited and Heritable Development Finance (together the Group), which primarily focuses on carefully selected sub-sectors of the mortgage market. The Group’s specialist lending is supported by a stable retail savings franchise with 150 years of heritage. Also part of the Group is the Bank’s overseas subsidiary, OSBIndia, based in Bangalore, which provides primary processing for the Kent Reliance brand.
Given the nature of the Group’s business, we believe there is a low risk of slavery or human trafficking having a connection with our business activities. However, there is no room for complacency in that belief and this statement sets out our approach in guarding against it.
We have an established Group Vendor Management Outsourcing Policy which ensures that a robust framework is followed to efficiently manage potential and contracted third party relationships and comply with regulatory obligations.
The Bank continues to comply with Financial Conduct Authority rules in SYSC 8 ‘Outsourcing’. This requires us to:
- take all reasonable steps to avoid undue additional operational risk; and
- take all reasonable steps to ensure that a Service Provider has the ability, capacity and authorisation required by law to perform the outsourced functions, services or activities reliably and professionally.
All Group contracts are categorised according to their materiality, in accordance with the above. Our due diligence questionnaire contains a specific question in regards to how the provider adheres to the Modern Slavery Act. Having reviewed the provisions of our material contracts we are satisfied that they would allow us to take appropriate action if any aspect of modern slavery was found to be taking place in any part of our business or supply chain.
We have further increased the monitoring of risks in our supply chain by working with Dun & Bradstreet to assess the potential risks for human trafficking in our supply chain. Initial analysis showed that when considering all of our suppliers, 93% were rated 1 out of 7, 1 being the lowest risk, 2% were rated 2, and the remaining 5% were not covered by the analysis.
The policies we have in place reflect our commitment to:
- acting ethically and with integrity in all our business relationships; and
- implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Relevant policies include Recruitment and Selection, Diversity and Equality (including references to pay and benefits) and Ethics. We have a comprehensive Whistleblowing Policy through which the Group encourages its employees and others who have serious concerns about wrongdoing or suspected wrongdoing in the workplace to come forward and voice those concerns.
OSBIndia is also an equal opportunity employer and fully committed to the equal treatment of its employees and job applicants. Its handbook contains a non-discrimination statement which states that the company will not discriminate against any employee or applicant on similar grounds to that in the United Kingdom, but also addressing discrimination highlighted in the modern slavery guidance including caste, national / provincial extraction and lawful political belief.
Our Group Vendor Management Outsourcing Policy ensures that a number of due diligence checks are undertaken and documented by Relationship Owners before we engage with suppliers and annually throughout the term of the engagement. Relationship Owners are required to make additional enquiries in the procurement processes for goods, services and locations where they are assessed as having a high risk of modern slavery and/ or human trafficking.
Ongoing monitoring of vendors includes the right to:
- carry out an assessment of anti-slavery controls
- check for any incident / compliance breaches.
Last year we developed a Vendor Code of Conduct for Labour Standards which sets out the minimum standards with which we require our vendors to comply. This has been sent to all of the Group’s vendors and enables Relationship Owners to communicate our expectations that suppliers must prohibit modern slavery and human trafficking in the supply chain and that they should work with their suppliers at each stage in their supply chain to manage slavery and human trafficking risk.
To ensure group wide awareness of this issue, we developed in-house a new training module covering modern slavery and human trafficking for all employees in the Group. We are also introducing more in depth training to educate relevant employees, including Relationship Owners, on the importance of implementing and enforcing effective systems to ensure slavery and human trafficking is not taking place within our business or suppliers.
Over the past year, no modern slavery incidences have been reported internally, giving confidence that our current policies are proving effective. However, we will continue to review policies, process and controls and monitor our supply chain to identify areas of high risk or emerging risks.
All employees are required to complete our in-house training module highlighting the risks and responsibilities regarding modern slavery and are thus aware of the steps to take should they suspect incidences of modern slavery.
100% of our current suppliers have received our new Vendor Code of Conduct informing them of our commitment to operating in an ethical and honest way and, as part of this commitment, asking our suppliers to expect the same standards of their own supply chain.
With our initial risk assessment performed by an external consultant, 0% of our suppliers were considered to be of higher risk regarding geographic location and commodity provision.
We are committed to growing and developing our understanding of the issues in order to minimise the risks involved in modern slavery and will continue to actively engage with our existing and new suppliers.This statement has been approved by the OSB Board and is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group's slavery and human trafficking statement for the financial year ending 31 December 2017. This statement will be reviewed and updated (if necessary) annually to reflect the group’s ongoing goal to ensure that our business and its supply chains are free from slavery and human trafficking.
Chief Executive Officer
ONESAVINGS BANK PLC
Date: 21 June 2018