1. MANAGING POLITICAL ACTIVITIES
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.
Our commitment to ethical behaviour and conduct means that we abide by not only the letter, but also the spirit of applicable acts of Parliament and regulation and, in particular, with regard to political activities to prevent against bribery, corruption or reputational risks associated with political activities. We do not compromise on the legal, regulatory or policy requirements that govern our activity.
2. POLICY AND PROCEDURES
Political activities cover contributions, engagement with public officials through advocacy, and the recruitment of staff from the Public Sector (‘Revolving Door’). The Bank of London ensures that any political activities it engages in are confined to legitimate advocacy on matters relevant to The Bank of London, its clients and the banking industry. The Bank of London will ensure that its advocacy activities are not, and cannot be perceived to be, seeking to secure any form of improper business advantage or influence governmental actions for The Bank of London. This includes complying with its Bribery Act Policy, its financial crime obligations and adhering to all applicable governmental laws, policies, and guidance governing interactions with public and governmental officials.
Consequently, The Bank of London seeks to embed the requisite policies and controls to ensure that its employees (including permanent employees, fixed term contractors, directors, and non-executive directors) globally understand these obligations and abide by them. The same applies to any other party with whom we do business, whenever they act for or on behalf of The Bank of London. All employees are specifically required to comply with our Global Policy Framework, which sets out our framework for managing potential risk to our organisation.
Our overall approach is framed around and based on the values of integrity, legitimacy, materiality, consistency, accountability, and oversight. Our policies, procedures and systems are specifically designed to meet these values, acts of Parliament and regulations, shareholder, and stakeholder expectations. The ways in which we manage the associated risk of our political engagements include:
Identifying and managing memberships of organisations The Bank of London engages in advocacy;
An integrated approach to all aspects of political activities;
Conducting a regular risk assessment to identify, control and mitigate associated risks;
Performing monitoring and assurance activity to identify potential concerns;
Transparency in all matters.
3. POLITICAL CONTRIBUTIONS
The Bank of London is an apolitical organisation with a standing policy of not making contributions to any political party. Donations (financial or in kind) to political parties, individuals or campaigns are not permitted on its behalf.
Earning our clients’ trust includes understanding the impact of government policy to ensure our products and services are right for our clients (and their customers) and meet legal and regulatory requirements. As a result, we may be invited to participate in government consultations and policy discussions to share our industry expertise and perspective and to inform their deliberations.
Any engagement with governments or policymakers is typically conducted alongside financial institutions and other corporate and non-corporate organisations operating in the United Kingdom (UK). The Bank of London will engage with governments (UK and devolved), parliamentarians and policymakers at executive and working levels. We respond to public consultations from a range of public organisations, such as His Majesty’s Treasury (HM Treasury), the Prudential Regulatory Authority (PRA), the Financial Conduct Authority (FCA), accept invitations to appear before select committees and parliamentary groups, and participate in joint task forces to outline our insights and perspective on industry matters.
5. THIRD PARTIES
The Bank of London is a member of several trade associations as part of its involvement in consultation on local, national UK, European Union, and United States legislation. Ensuring that The Bank of London’s active and comprehensive representation on trade associations is crucial as part of understanding upstream risks. Our Director of Corporate Affairs & Community Engagement works closely with employees and non-executive directors to identify representation that The Bank of London should pursue to ensure and that we are actively engaged where required and that we manage associated risks.
When engaging with any third party, intermediary or partners, we require compliance with all applicable local and national laws, and where appropriate applicable The Bank of London policies and procedures, to ensure they are acting in an ethical and lawful manner – always.
The Bank of London has controls in place to manage the exchanges of people between the public sector and The Bank of London through the recruitment process (including secondments). An assessment of the risk posed is undertaken and any mitigating controls imposed (such as cooling off periods), if required.
To the extent that The Bank of London decides to hire an individual who is or has been affiliated in any way with the public sector and/or political parties (“Relevant Individual”), it will conduct prior due diligence and vetting on the Relevant Individual. This due diligence will include obtaining disclosure of the Relevant Individual’s significant commitments and business interests they have outside of their proposed role in The Bank of London so that The Bank of London is able to assess potential conflicts of interest between it and the Relevant Individual. This due diligence will be in addition to the information collated and requested by The Bank of London in accordance with its obligations under the Prudential Regulatory Authority’s (PRA’s) and Financial Conduct Authority’s (FCA’s) Senior Managers & Certification Regime.
Where the Relevant Individual has worked in a UK ministerial office or in the Crown’s service in the last 2 years, The Bank of London will seek confirmation that the Relevant Individual has applied for and obtained advice in accordance with Government Guidance from the Advisory Committee on Business Appointments and has complied with all applicable guidance issued by this body(1).
In addition, the service agreement or employee contract entered by the Relevant Individual will contain provisions which require the Relevant Individual to inform The Bank of London in advance of any changes to significant commitments or business interests. In certain circumstances, the Relevant Individual may be required to seek approval from The Bank of London before accepting further commitments or entering into business interests which either might give rise to a conflict of interest or a conflict with any of the Relevant Individual’s duties to The Bank of London.
The Relevant Individual will also be required to disclose to The Bank of London any actions which could reasonably be expected or lead to unwanted or unfavourable publicity to The Bank of London.
Responsibility for the co-ordination and oversight of political activity – including monitoring, analysis, and development of policy positions, legislative responses, and engagement with political and legislative stakeholders (including through events and one-to-one meetings) rests with The Bank of London’s Director of Corporate Affairs & Community Engagement. (1) Business Appointments - making applications under the Rules for former ministers and senior Crown servants - GOV.UK (www.gov.uk)