1. OVERVIEW

The Bank of London conducts business ethically, honestly, fairly, and transparently. How we conduct ourselves is critical to our success. We strive to maintain and adhere to the highest standards of governance and ethical conduct in everything we do.

This statement is made pursuant to section 54 of the United Kingdom’s Modern Slavery Act 2015 and sets out the steps that The Bank of London take to ensure that modern slavery or human trafficking does not occur within our business or our supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. The Bank of London has a zero-tolerance approach to any form of slavery and trafficking. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within our business or our supply chain.

This is The Bank of London’s first anti-modern slavery and human trafficking statement. It explains what we have done so far; what measures we have in place to prevent it; and next steps. As we develop our plans further, we will update this statement too.

2. WHO WE ARE

We are The Bank of London Group Limited (or "The Bank of London", but we may also use “TBOL”, "we", "us", or "our" to refer to The Bank of London throughout in this statement).

The Bank of London is a company registered in England and Wales under registered number 12844788. Our registered address is at 100 Bishopsgate, City of London, EC2N 4AG, United Kingdom.

We are a bank authorised by the Bank of England’s Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Bank of England’s Prudential Regulation Authority under Financial Services Register number: 930379.

3. OUR POLICIES ON MODERN SLAVERY AND HUMAN TRAFFICKING, DUE DILIGENCE AND RISK MANAGEMENT

We are committed to preventing modern slavery or human trafficking in our business and our supply chains. For us, good business and ethics go hand in hand.

Our current policies are:

OUR PEOPLE: We are committed to a workplace culture that reflects our values of diversity, fairness, compassion, and non-discrimination. Our staff is recruited legally, and we comply with the United Kingdom’s Immigration Act 1998. We have a whistleblowing policy in place and a whistleblowing champion.

OUR CUSTOMERS: To ensure our clients and their customers are protected against modern slavery:        

• We assess our clients’ applications against our ethical statement and conduct due diligence in line with our anti-money laundering policy.

• We will end relationships with clients if there are indicators or concerns about modern slavery or trafficking and report it to the authorities (National Crime Agency following a Suspicious Activity Report).

• We have financial crime teams made up of subject matter experts, which will investigate any suspicious activity or risk in this field.

• We train our staff extensively. All new hires undertake mandatory training on economic crime, conduct risk and anti-money laundering. Specialist teams, such as the risk and compliance team and customer service team, undertake additional training including on customer due diligence, complying with sanctions, and fighting fraud. The client services teams are trained on identifying and supporting vulnerable customers and referring them to third party experts who can assist them.

OUR MARKETPLACE PARTNERS: We expect partners to adhere to The Bank of London’s standards. We request a copy of the anti-modern slavery statement for our largest Marketplace partners, both at onboarding and as part of annual due diligence review.

4. OUR SUPPLIERS

The Bank of London utilises services from third parties predominantly located in the United Kingdom, United States and European Union. To tackle slavery and trafficking in our supply chain we:

• Incorporate anti-slavery obligations into agreements with suppliers where relevant and on a risk-assessed basis.

• Adopt a risk-based approach in identifying, monitoring, and assessing suppliers who are at a greater risk from instances of slavery and trafficking taking appropriate mitigating actions.

• Perform due diligence and relationship oversight in line with the Supplier & Outsourcing Policy and Third-Party Management Procedure, ensuring Vendors meet The Bank of London’s expectations on an ongoing basis.

• We will work with the government, regulators, and law enforcement to help identify and tackle modern slavery and human trafficking.

• Compliance with all applicable laws, including modern slavery, forms part of our contract that we look to put in place with key suppliers. The Bank of London will only deal with third parties where we are satisfied the third party operates in a manner consistent with The Bank of London’s core values.

5. LOOKING AHEAD

As this is our first statement, there is more that we can do. In the next few months, we will develop a more comprehensive anti-modern slavery statement, increase our training, and strengthen our processes where necessary.

6. STATEMENT APPROVAL

This statement was approved by the Group Board of Directors and the United Kingdom Board of Directors in November 2021.