Modern Slavery Statement - Lloyds Banking Group
MODERN SLAVERYAND HUMANTRAFFICKINGSTATEMENTLloyds Banking Group2020
Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2020 02About Lloyds Banking GroupWe are a UK financial services provider witharound 25 million customers and a presencein nearly every community. Lloyds BankingGroup plc has a number of subsidiaries,a full list of which can be found in our AnnualReport. Our main business activities are retailand commercial banking, general insuranceand long-term savings, provided through wellrecognised brands including Lloyds Bank,Halifax, Bank of Scotland, MBNA andScottish Widows.Inside this year’s StatementModern Slavery and Human Trafficking Statement 2020Our PoliciesOur Suppliers – assessing and managing riskCombatting modern slavery and human traffickingas a financial crimeBusiness customersWorking with survivorsTrainingGovernanceLooking ahead030406080910111112Our active supply base comprises approximately 3,000 suppliers, the majority ofwhich are in professional services sectors such as management consultancy, legal,HR, IT, operations, marketing and communication.Our suppliers are located inthe UK, other European countries, North America and Asia (see ‘Our Suppliers– assessing and managing risk’ for more detail). Our shares are quoted on theLondon and New York stock exchanges and we are one of the largest companies inthe FTSE 100 index.25m25 million customers anda presence in nearly everycommunity98%98 per cent of ouremployees work in the UK3,000Our active supply basecomprises approximately3,000 suppliersFind out moreAbout our Group in 2020,Annual Report and Accounts
Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2020 03Modern Slavery and Human Trafficking Statement 2020This Statement outlines thesteps we have taken in thelast twelve months to combatthe risk of modern slaveryand human trafficking takingplace in either our businessor our supply chains, and ourfocus areas for the year ahead.In 2020 we had no reportedincidents.This is our fifth Modern Slavery andHuman Trafficking Statement. It is made inaccordance with section 54(1) of the UK’sModern Slavery Act 2015 and applies toLloyds Banking Group plc, its subsidiaries,employees and officers of the Groupfor the financial year ending 2020.This Statement was approved in February2021 by the Board of Lloyds BankingGroup plc on behalf of all the Group’ssubsidiaries, and by the Boards of itsprincipal subsidiaries Lloyds Bank plc,Bank of Scotland plc and HBOS plcon behalf of the Ring Fenced Banksub-group. The Boards of Lloyds BankCorporate Markets plc and ScottishWidows Group Limited approved theStatement on behalf of the Non RingFenced Bank sub-group and theInsurance sub-group respectively.The impact of coronavirusThe coronavirus pandemic (Covid-19) hascreated unprecedented challenges forour customers, communities, colleaguesand suppliers. We have worked hard toprotect the health, livelihoods and accessto critical financial services for all of thesegroups. However, we are acutely awarethat this pandemic may have createddifferent risks for modern slavery, forinstance, we know that it has been harderfor all sectors to conduct due diligencein person. We have not relaxed ourstandards and the expectations we setfor ourselves and our suppliers. Insteadwe have looked for other ways to conductcritical checks, in line with governmentguidance. For instance, right to work andalternative identification checks now takeplace online through video calls.Despite the disruption caused byCovid-19, we have continued to makeprogress on each of our identifiedpriority areas below, even where externallimitations imposed on our colleaguesand on our partners have made progressslower than we would have liked. Fullerdetails on actions taken can be found inthe sections below:C ontinuing to regularly review oursupplier risk assessment processes –including piloting new toolsR aising colleague awareness ofmodern slavery and human trafficking– including introducing new training Strengthening external partnershipsand collaborations – includingcollaborating with more local charities Integrating modern slavery and humantrafficking considerations into ourrelationships with clients – includingnew due diligence requirementsOur commitment to human rightsA responsible and sustainable approachto doing business is central to our strategyand our purpose to help Britain prosper.Our work to tackle modern slavery formspart of our wider work to embed humanrights considerations into our business.We believe in the importance of doingbusiness in ways that value and respecthuman rights – of our colleagues,customers, business partners andeveryone that is affected by our business.We do not tolerate slavery, trafficking orforced labour in any part of our businessor supply chains. This is reflected in howwe are embedding these considerationsacross our business. By way of example,in the UK (where 98 per cent of ouremployees work) we have aligned ouractivities and policies with internationalbest practice and recognised standards.We are either a signatory to, or abide by,the principles of a number of internationaland national codes and standards relatingto responsible business practice. Theseinclude: The Equator Principles, the UNPrinciples for Responsible Investment, theUN Global Compact, the UN UniversalDeclaration of Human Rights, theInternational Labour Organisation’s CoreLabour Standards, the UN EnvironmentProgramme Finance Initiative (UNEP FI)Principles for Responsible Banking andthe Principles for Sustainable Insurance.We do not tolerateslavery, trafficking orforced labour in anypart of our businessor supply chains.
Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2020 04Our PoliciesWe have a number of internalGroup policies and proceduresin place that reflect ourcommitment to operatingresponsibly and ethically asa business and as individualemployees. These policies andprocedures help us to embedhuman rights considerationsinto our operations.Our policies cover a number of criticalareas including; Colleague, Sourcing,Speak Up (whistleblowing) and Anti-Bribery.Each business area is required to set itsstrategy in line with our risk appetite andour policy requirements. These Grouppolicies, associated procedures andmandatory training are reviewed annuallyas part of the governance of the Group’sPolicy and Risk Management Frameworks.This annual review reflects our effortsto continually improve our responsiblebusiness governance approach, andto further embed human rights intoour business.Our Human Rights Policy Statementprovides an overview of the work we do tosupport and protect human rights withinour business and communities, and isguided by the United Nations GuidingPrinciples on Business and Human Rights.Our ColleaguesOur Values and Behaviours are theguiding principles for how we work. OurCode of Ethics and Responsibility (theCode) provides an overarching frameworkto ensure the highest possible standardsof behaviour and underpins our approachto being a responsible, ethical, sustainableand inclusive business, for customers,colleagues, communities, the environmentand our external stakeholders. It includesa section that outlines the ways in whichrespect for human rights should informcolleagues’, contractors’ and temporaryemployees’ actions and decisions.The Code, which was updated this year,encourages colleagues to report, throughour whistleblowing service, Speak Up,or to their line manager, any actions thatare unsafe, unethical, unlawful, or not inline with Group Policies.We have recognition agreements with twotrade unions that collectively negotiate onbehalf of our UK workforce (around 98 percent of colleagues worldwide). The UK’sLiving Wage Foundation has accreditedthe Group as a Living Wage Employer.We review our pay rates annually to ensureminimum rates are above the statutoryminimum and living wage requirementsthat are applicable in the countries weoperate in. We have worked, and continueto work, with third-party contractorsto ensure that they operate in line withour commitments and expect them toensure that the wages they pay meetlegally mandated minimums withoutunauthorised deductions.In our internal operations, our ColleagueScreening Standards apply to allpermanent and non-permanentemployees that we recruit, includingtemporary staff and contractors. Thisprocess upholds our respect for labourrights and, for our UK employees, includesthe review of individuals’ proof of identity,address, and right to work in the UK.Normally these are conducted face toface, but given the health risks of Covid-19,we have followed government adviceand temporarily adjusted these checks.Since 30th March 2020, these checks arenow carried out via video conference –minimising health risks, while maintaininga robust process.98%We have recognition agreementswith two trade unions that collectivelynegotiate on behalf of our UKworkforce (around 98 per cent ofcolleagues worldwide)The Group uses a number of recruitmentagencies and service providers to fill roles.UK agencies are bound by contracts whichrequire compliance with our ColleagueScreening Standards and the Code ofSupplier Responsibility, and whichinclude specific Modern Slavery andAnti-Bribery clauses. UK agencies alsoattest compliance annually via theFinancial Services Supplier QualificationSystem (FSQS).Find out moreCode of Ethics and ResponsibilityAnti-Bribery Policy StatementHuman Rights Policy Statement
Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2020 05Our Policies continuedOur SuppliersResponsible sourcing is integral to theway we do business. All colleaguesengaged in sourcing follow the definedBusiness Sourcing Process and undertakesourcing in line with the requirementsof our Sourcing & Supply ChainManagement Policy.We expect suppliers to meet or exceedthe provisions in our Code of SupplierResponsibility which we share throughthe supplier contract as governed by ourBusiness Sourcing Process. It definesour expectation in terms of responsiblebusiness behaviour, including humanrights and labour issues in the countriesand communities in which they operate.We require those suppliers going throughthe FSQS to confirm they have read,understood and complied with theCode of Supplier Responsibility andprovide us with evidence to demonstratetheir approach.We regularly review our Code of SupplierResponsibility to embed responsiblebusiness and sustainability further intoour business, and we commit to workingcollaboratively with our suppliers ondeveloping our approach to responsiblesourcing and sustainable procurement.As outlined in the Code of SupplierResponsibility, we expect our suppliers torespect human rights, both in their ownworkforce and those in their supply chain,including to:E xplain the principles of the Codeof Supplier Responsibility to theiremployees and key sub-contractorsthat support the Group or work onour projectsR espect the human rights of theiremployees and comply with all relevantlegislation, regulations and directives,including awareness and mitigation ofthe risk of modern slavery in the countriesand communities where they operateincluding, where relevant, compliancewith the UK Modern Slavery Act Prohibit forced labour (slavery) andhuman trafficking in their supply chainand give their employees the rightand ability to leave employment ifthey chooseP rohibit child labourE nsure that wages meet legallymandated minimums withoutunauthorised deductionsAllow their employees to exercisethe legal right to organise and joinassociations (such as labour unions)P rovide clear and uniformly applieddisciplinary and grievance proceduresincluding prohibiting mental, physical orverbal abuseE nsure working hours are in accordancewith local regulation and industrypractice and voluntary overtime is ata manageable levelAs set out in our Group Sourcing andSupply Chain Management Third PartyPolicy, we expect suppliers to managetheir own suppliers in a responsible andsustainable manner to mitigate supplychain risks and to proactively work withsuppliers who represent a material riskon such issues. For example, to mitigatethe risk that purchasing practices putundue pressure on workers in their supplychain, which can contribute to modernslavery risks, we expect suppliers to havereasonable payment policies alignedto our own commitment to the PromptPayment Code.Our suppliers are also asked to complywith specific Third-Party Supplier Policies,tailored to the services they provide tothe Group. Third party policies such asAnti-Bribery, Data Privacy and Fraud,are documents which:A rticulate Lloyds Banking Group’sexpectations in regards to behavioursand decision makingAddress the primary areas of risk whichLloyds Banking Group facesTranslate Lloyds Banking Group’s riskappetite into mandatory requirementsand controlsOur suppliers have a contractualobligation to comply with all applicablelaws that apply to their supply of goodsand services to us, regardless of thejurisdiction in which they operate.We also include compliance with theCode of Supplier Responsibility andGroup policies as they relate to modernslavery and standalone modern slaveryclauses in our supplier contracts andpurchase order standard terms andconditions. These clauses seek to:m anage and maintain oversight overmodern slavery risks;e nsure that we receive appropriateinformation on suppliers’ due diligenceprocedures to monitor modern slaveryrisks, including for its own supply chainsand organisations;r equest copies of their modern slaverystatements if a supplier is required toreport under the UK Modern SlaveryAct or an annual modern slavery reportsetting out steps the supplier has takento monitor modern slavery and ensure itis not taking place in its own business orits supply chains; andSpeak upWe encourage suppliers to speak up if they are concernedabout any actions or decisions that contravene the standardsset out in the Code of Supplier Responsibility and we offerour suppliers access to our confidential Speak Up Linewhere they and their workers can report any incidents.An independent supplier manages the line and we haveworked with them to ensure that, if instances of modernslavery or other human rights abuses are reported, they areidentified and effectively investigated. This formal processis intended to be both sensitive and robust. The identityof those who raise a concern is not disclosed withouttheir permission and there is an option to raise concernsanonymously. The Speak Up Third-Party Policy has beendesigned to assist in managing any risk that Third-PartySuppliers’ employees are prevented from reportingany concerns about risk, malpractice or suspectedwrongdoing. There were no reported modernslavery incidents through Speak Up in 2020.f acilitate termination of the contractwhere a supplier, or any participantsin its supply chain, are engaged in anypractice or activity that would constitutean offence involving modern slavery.These clauses are very rarely negotiatedby Group suppliers, however, if weencounter any supplier amendments wego through an escalation and sign offprocess with the business to consider therisks of any supply contract, particularlywhere there is deviation from our standardclauses. The clauses related to modernslavery specifically are mandatoryand cannot be negotiated withoutlegal support.Find out moreCode of Supplier ResponsibilityThird Party Supplier Polices
Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2020 06Our Suppliers – assessing and managing riskIt is important that we have theright framework to operateresponsibly and beforeselecting suppliers, we followa due diligence process, whichevaluates them against keycriteria, including their humanrights programmes.Lloyds Banking Group subscribes to theFSQS, a third-party managed supplierqualification system for the financialsector that is currently used by morethan 30 major banks, building societiesand insurance companies. This ensureswe adopt a standardised approach tocompliance and assurance, which formsan integral part of our supply chainmanagement.We take a risk-based approach andcontractually require our c.1,100 managedsuppliers to self-attest their complianceto the Group’s policy expectations onan annual basis. As part of the FSQS,these suppliers are asked to provideevidence of processes and proceduresfor assessing and complying with relevanthuman rights legislation and labourstandards, including the UK ModernSlavery Act. We require that suppliersidentify human rights risks such as modernslavery in their supply chain and monitorand assess their suppliers’ human rightsperformance. Suppliers must completethe FSQS questions on an annual basis,and employees who manage the supplierrelationship (Supplier Managers) mustconfirm that this is satisfactorily completedthroughout the duration of the supplier’scontract with the Group. If a supplierprovides a non-compliant answer to anyresponsible business FSQS question suchas the occurrence of an employmenttribunal in the last three years, or noncompliance with the UK Modern SlaveryAct, Supplier Managers are requiredto investigate and manage through toresolution. Where a supplier fails to meetthe expectations set out in the Code ofSupplier Responsibility, we commit toworking with them to developan improvement plan, however if the issueis deemed sufficiently serious or cannotbe resolved in a reasonable timeframe,the Group may undertake a review of theterms of the contract, which could includetriggering the right to terminate wheremodern slavery issues have arisen.The Group regularly reviews the FSQSrisk framework. In 2019 we introducedadditional questions that trigger a ‘redflag’, prompting further investigativeaction and remediation and we arecurrently exploring how new technologycan enhance supplier managers’ use ofFSQS data, for example, to ensure thatthey are focused on the most pertinentrisks associated with that supplier.The Group Sourcing Supplier Assuranceteam conducts an annual programmeof assurance reviews for suppliers whichrepresent the highest risk exposure to theGroup. Suppliers that trigger agreed riskcriteria are selected for an onsite supplierassurance visit to test the supplier’sadherence to relevant Group policies,which include assessment of modernslavery risks as appropriate. This yearwe have focused on strengthening ourhuman rights due diligence processes.For example, we have improved thehuman rights guidance in the supplierassurance test plan in line with our newCode of Supplier Responsibility. We havealso piloted a specialist third-partysustainability assessment tool with a smallselection of suppliers to provide insight ontheir management of issues including onlabour and human rights, and are in theprocess of a broader roll-out to targetedsuppliers. To increase the visibility of socialand environmental risks in our supplychain we are also piloting a supplier riskmanagement tool that equips SupplierManagers with relevant real-time dataincluding media feeds of reported issues.Given the disruption caused by Covid-19,we have made adjustments to how werun our due diligence of suppliers. Wehave made no changes to our suppliermanagement framework or our minimumexpectations of our suppliers, so wecontinue to maintain the same highstandards, albeit how we meet thesehas changed. For example, it has notbeen possible to conduct physical onsitesupplier assurance visits since March,and so all reviews are being conductedremotely. This is part of a comprehensiveapproach to supplier management thathas aimed to minimise the health riskswhile protecting human rights acrossour supply chain – including a process toallow suppliers to work from home, wherepossible and without compromisingsecurity, and an approach to ensurethe continuity of necessary financialservices so that vulnerable customersare not adversely affected. Special billingarrangements were put in place betweenMarch and August for offshore supplierstaff who were not able to safely work fromhome or on site. These arrangementsallowed for a proportion of work thatcould not be completed to be billed – onthe proviso that all such staff continuedto be paid as normal. This approach wastaken to minimise the impact on supplierstaff in geographies where furlough orequivalent schemes were not operating.In 2020, there were no high priorityfindings and no relationships exited as aresult of issues with Modern Slavery.ResponsibleSourcingWe are committed to engaging withsuppliers to ensure that we achievethe best value for customers - interms of price and quality as well associal impact and we are integratingthis into our purchasing decisions.For example, when we undertook amarket review of who should supplythe uniforms for our network branchcolleagues, a key element of ourevaluation methodology was toassess suppliers according to theirCorporate Social Responsibilityrating. Given the potential labourrisks associated with the garmentindustry, it was agreed that thesuccessful supplier must be anestablished member of the EthicalTrade Initiative, which is a leadingalliance of companies, trade unionsand NGOs that promotes respectfor workers’ rights. It was alsoagreed with the selected supplierthat they would provide auditableevidence to the Bank that theirfabric and garment manufacturersare complying with the relevantethical and workers’ rights standards,including giving the Bank directaccess to audits conducted byindependent third-parties.We also engage with suppliersto strengthen their due diligenceto mitigate modern slavery risks.For example, as a result of ourdiscussions, the Group’s mainmanaged service provider fortemporary administrative workers isnow affiliated with the Recruitmentand Employment Confederation(REC) who are part of the SaferJobs network, a joint industry andlaw enforcement organisationthat works to prevent labourmarket exploitation, includingmodern slavery. The provider alsoencourages agencies in their supplychain to be affiliated with REC orSafer Jobs directly.Find out moreWorking with suppliers
Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2020 07Our Suppliers – assessing and managing risk continuedWe have analysed our suppliers based ongeography, service sectors and spend.The majority of our direct suppliersrepresent a traditionally low risk of modernslavery. According to the Global SlaveryIndex, 99.8 per cent of our supplier spendis incorporated in geographies that areconsidered low risk for modern slavery;95.3 per cent of our supplier spend isincorporated in the UK, 3.2 per cent inother European countries, 1.3 per centin North America and the remaining0.2 per cent in other countries, includingIndia, the Philippines, Israel and HongKong. Additionally, 82 per cent of ourexternal supplier spend is in servicesectors considered low risk, and analysisof the remaining 18 per cent potentialhigh risk service sectors shows that98 per cent of spend has a suppliermanager assigned, and is covered bythe FSQS. We will continue to monitorand seek to continuously improve ourprocess of identifying risks.Our suppliers in India and the Philippines,including IT providers, are large globalfirms which have undergone rigorous duediligence and are managed by dedicatedSupplier Managers.OUR SUPPLIER GEOGRAPHYOUR SUPPLIER SPEND82%of our external supplierspend is in service sectorsconsidered low risk1.3%North America95.3%of our supplierspend is incorporatedin the UK0.2%3.2%Other EuropeancountriesOther: India,Philippines, Israel andHong Kong18%potential high riskservice sectors98%of spend has a suppliermanager assigned,and is covered bythe FSQS
Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2020 08Combatting modern slavery and human trafficking as a financial crimeThe financial sector has animportant role to play in thefight against modern slaveryand human trafficking (MSHT),as there may be exposurethrough the receipt andmovement of the proceedsof crime. The Group is awareof the risks and the influenceit can have in combattingmodern slavery through itsfinancial crime approachand we have implementedand continue to strengthenmonitoring controls to helpidentify activity which may beindicative of exploitation andproceeds relating to MSHT.The Group takes a proactive role inidentifying potential MSHT perpetratorsand the Group Fraud and Financial CrimePrevention’s Financial Intelligence Unit(GFIU) has made human trafficking andmodern slavery a primary area of focus.The GFIU seeks to better understandthe MSHT threat to the Group to makeaccurate and insightful assessmentsthat inform our risk-based approach andresponse. GFIU continuously seeks toobtain intelligence on MSHT to createa baseline understanding of the threatand its scale, and track changes overtime. Whilst intelligence available onMSHT is limited, GFIU regularly engageswith intelligence providers such aslaw enforcement, charities and otherorganisations working to counter MSHT.We have developed specific typologiesto identify and target financial indicatorsassociated with sexual and labourexploitation and organised immigrationcrime and continue to innovate thesein line with intelligence on the evolvingnature of modern slavery. This issupported by our Group VulnerabilityStrategy which includes training forour retail colleagues on how to identifysuspicious activity and customers underduress that could indicate such crimes.A sustained area of focus for the Groupis on tackling the rise of child victimsof modern slavery associated with CountyLines drug trafficking operations in theUK. This often involves the intimidation,financial exploitation and endangermentof young and vulnerable people insmaller towns and rural areas.We work with the National County LinesCo-ordination Centre to support Groupcolleagues in spotting behaviouraland transactional indicators and tounderstand how these are evolvingas County Lines dealers adapt to thecoronavirus pandemic.The Group is aware that Covid-19 maylead to new or increased risks of modernslavery, for example by heighteningpeople’s vulnerability to labourexploitation. To address this, GFIU hasdelivered training to over one-hundredfirst line colleagues in Retail andTransaction Monitoring to help themunderstand these new emerging threatsand the transactional risk indicators theyshould look out for. Additionally, thisyear, as part of Fraud and Financial CrimeAwareness month, the Group’s Fraudand Financial Crime Prevention teamproduced a webinar on how the modernslavery and human trafficking landscapehas changed in response to Covid-19.Open to all colleagues from across theGroup, the webinar was led by subjectmatter experts from the anti-slaverycharity Hope for Justice.The Group’s Fraudand Financial CrimePrevention teamproduced a webinar onhow the modern slaveryand human traffickinglandscape has changedin response to Covid-19.
Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2020 09Business customersWe know that financialinstitutions, as providers ofcapital, have an important rolein tackling modern slavery andhuman trafficking and we seekto avoid the risk that we mightbecome linked through ourbusiness relationships to anyform of modern slavery.We regularly review all of our customersthat we have a direct banking relationshipwith. Where they appear to be operatingoutside of our risk parameters, we willwork with our customers to understandhow they plan to transition to meet ourrisk parameters. If the customer does nottransition, we will exit the relationship atthe earliest opportunity. We have regularengagements with our customers (whereappropriate) that we have a direct bankingrelationship with, and regularly reviewtheir public filings, press reports andanalyst presentations.Insurance and savingsIn 2020 we workedto further integratemodern slavery andhuman traffickingconsiderations intoour relationshipswith clients.As a UK focused financial servicesprovider, the vast majority of our assetsare in developed markets which areassociated with lower risks of modernslavery. However, we know that modernslavery occurs all over the world, includingin the UK, so we apply our strong riskmanagement culture to further minimiseany risks.In 2020 we worked to further integratemodern slavery and human traffickingconsiderations into our relationships withclients. Our external sector statementsdetail our expectations for corporatecustomers and specify that we expectthem to respect human rights, both oftheir own workforce and in their supplychain. We require them to comply withapplicable international conventions,sanctions and embargoes, legislation,and licensing requirements whilstshowing a clear commitment to robustEnvironmental, Social and Governance(ESG) risk management.Within Commercial Banking, ESGcommentary requirements have beenembedded into the credit assessmentprocess. ESG risks, including modernslavery, must now be specificallycommented upon where credit limitsexceed 500,000 to help inform theoverall credit view. During 2020 additionalguidance has been added to CommercialBanking internal credit policies forsectors where the prevalence of low paid,temporary and migrant workers exposesthe sector to risks of modern slavery.This guidance specifies the due diligencethat relationship managers are requiredto conduct including reviewing the stepstaken by the client to ensure that thereis no slavery in their business or itssupply chain.We act in accordance with the UN GlobalCompact which includes the principlesthat businesses should make sure thatthey are not complicit in human rightsabuses and should uphold the eliminationof all forms of forced and compulsorylabour. As outlined in our Exclusion Policy,we do not invest in companies identifiedas violators of the UN Global Compactunless we believe we have sufficientleverage to influence their behaviour overa three-year period. If companies fail tocomply with the UN
Modern Slavery and Human Trafficking Statement 2020 03 Our Policies 04 . for all sectors to conduct due diligence in person. We have not relaxed our . and national codes and standards relating to responsible busines
3 Climate-induced migration and modern slavery Contents About the authors 4 Acknowledgements 5 Executive summary 6 Chapter 1: What is ‘modern slavery’? 11 1.1 What is modern slavery and what forms does it take? 11 1.2 Who is impacted and at risk? 12 1.3 Drivers of modern slavery 13 Cha
Modern Slavery Statement 2020 Page 2 of 10 BAM Nuttall Ltd Modern Slavery Transparency Statement 2020 The BAM Nuttall Board make this statement on behalf of BAM Nuttall and its subsidiaries for the calendar year 2020. It sets out what we are doing to stamp out slavery and human trafficki
operations through its supply chain. AC3 primarily addresses the risks of modern slavery practices occurring in its operations and supply chain through its newly formed Modern Slavery Policy. This policy takes a risk and materiality approach to identifying and investigating potential modern slavery within the businesses operations and supply chain.
modern slavery and human trafficking within our business. As required by the Modern Slavery Act 2015 (the "Act"), this statement describes the steps that the Phoenix Group has taken during the financial year ended 31 December 2019 to prevent modern slavery from taking place in our supply chains and within our own business. 2
Lloyds' insurance business offers a degree of franchise differentiation from U.K. peers. Lloyds' subsidiary Scottish Widows is a leading provider of life and pensions and investment business, and has one of the largest intermediary sales channels in the U.K. It also underwrites general insurance products through other subsidiaries. We see growing
modern slavery and human trafficking and by 2025 end child labour in all its forms.4 With the goal firmly set, governments, businesses and campaigners have joined the fourth anti-slavery movement to help eradicate slavery for good.5 However, technological advancements for data collection on modern slavery could hold the key to end this fight.
trafficking and child labour. The 2017 Global Esti-mates of Modern Slavery and Child Labour found in the past five years, 89 million people experienced some form of modern slavery. Of these, 82.7 million were victims of forced labour, including trafficking, largely in the private economy. Modern slavery is per-
Scrum, Agile Software Development. with Ken Schwaber (Prentice Hall, fall 2001), a provocative book that assumes software development is more like . new product development. than the manufacturing-like processes that the software industry has used for the last 20 years. Arie van Bennekum. has been actively involved in DSDM and the DSDM Consortium since 1997. Before that he had been working .
