Modern Slavery Statement
This statement has been approved by the OSB Board and is made pursuant to section 54(1) of the Modern Slavery Act 2015. The statement incorporates both OneSavings Bank plc and InterBay ML Ltd and is for the financial year ending 31 December 2018. This statement will be reviewed and updated (if necessary) annually to reflect the Group’s on-going goal to ensure that our business and its supply chains are free from slavery and human trafficking.
Organisation's structure and business
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. The OneSavings Bank group is made up of a family of specialist financial services brands, namely, Kent Reliance, Prestige Finance, InterBay Commercial, InterBay Asset Finance 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 processing services to the Group.
Our supply chains and outsourcing activity
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 compliance 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.
In addition relationships with OSBIndia adhere to the Indian Labour Laws (Article 23 and 24 of the constitution of India).
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.
Relevant employment policies
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 and also addressing discrimination highlighted in the modern slavery guidance including caste, national / provincial extraction and lawful political belief (in compliance with the Indian Labour Law / Article 23 and 24 of the constitution of India).
Due diligence process
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 on-going throughout the term of the engagement. On-going monitoring of vendors includes the right to:
- carry out an assessment of anti-slavery controls
- check for any incident / compliance breaches
The Group has developed a Vendor Code of Conduct for Labour Standards which sets out the minimum requirements by which we expect our vendors to comply. In June 2018 we completed an exercise to ensure that this was sent to all of the Group’s vendors, providing clear communication of our expectations that they prohibit modern slavery and human trafficking both within their organisations and throughout the supply chain.
To ensure Group wide awareness of this issue, we have developed an in-house 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.
Our effectiveness in combating slavery and human trafficking
All employees are required to complete our in-house training module highlighting the risks and responsibilities regarding modern slavery, ensuring that they are aware of the steps to take should they have any suspicions or concerns.
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, processes and controls and monitor our supply chain to identify areas of high risk or emerging risks.
We have introduced internal controls to ensure that all new vendors receive our Vendor Code of Conduct and are aware of our expectation that they continue to operate in an ethical and honest way both within their organisations and throughout their own supply chains.
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.
Chief Executive Officer
OneSavings Bank PLC
Date: 21 June 2019
Group Chief Operating Officer
InterBay ML Ltd
Date: 21 June 2019