Slavery and Human Trafficking Statement 2019
This Statement is made pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 (the Act) and covers the period from 1 January 2019 to 31 December 2019. This statement sets out the measures that OneSavings Bank plc (OSB) and its subsidiaries (the Group) are taking to combat slavery and human trafficking in our businesses and supply chains.
This Statement is made on behalf of OneSavings Bank plc, Interbay ML, Ltd, Charter Court Financial Services Group plc, Charter Court Financial Services Limited and Exact Mortgage Experts Limited.
Our Structure and Business
OSB is listed on the London Stock exchange and is a member of the FTSE 250. OSB is incorporated in the UK and headquartered in Kent. The Group is made up of a family of specialist financial services brands, namely, Kent Reliance, Charter Court Financial Services, Prestige Finance, InterBay Commercial, InterBay Asset Finance and Heritable Development Finance, 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. OSBIndia, which is based in Bangalore, also forms part of the Group and provides internal processing services.
In October 2019, OSB finalised a significant and successful combination with Charter Court Financial Services Group plc (CCFS) and continues to work on alignment following this combination.
The Group, as at 14 April 2020, has 1,891 employees, temporary workers and contractors, primarily located at its main operating centres in Chatham, Wolverhampton, London (UK) and Bangalore (India).
Our Supply Chains
Our supply chains include suppliers of goods and services, including, but not limited to, maintenance of our premises, IT systems, software and hardware facilities, catering, recruitment and mortgage intermediaries.
We have established Vendor Management, Procurement and Outsourcing Policies which ensure that robust frameworks are followed in order to efficiently assess and manage potential and contracted third party relationships and compliance with regulatory obligations.
The Group 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.
The Group also complies with the European Banking Authority (EBA) guidelines relating to outsourcing arrangements which was introduced in September 2019.
In addition, OSBIndia and their supply chain adhere to the Indian Labour Laws (Article 23 and 24 of the constitution of India).
Our Policies on Slavery and Human Trafficking
Over the year, no instances of modern slavery were reported and we continue to ensure all relevant employment policies provide direct consideration of the risks associated with modern slavery. We are committed to ensuring that no modern slavery or human trafficking takes place in our supply chains or in any part of our business. Internal policies exist which aim to ensure we establish good practices and act ethically and with integrity. In compliance with the Act, we do not support excessive overtime and our employees in India are required to work in accordance with local legislation.
Due Diligence Processes for Slavery and Human Trafficking
The Group has zero tolerance for slavery and human trafficking. As part of our initiative to identify and mitigate the risk we:
- issue to identified suppliers, a Code of Conduct, documenting our expectation of compliance with modern slavery regulations and have incorporated, where appropriate, provisions in our contracts with them; and
- continue to enhance our ability to classify our third party services based upon the level of risk and incorporate the appropriate provisions in our contracts with them.
We provide guidance to the business owners responsible for recruitment and those having responsibility for the engagement and oversight of suppliers, which highlights the risks of modern slavery and human trafficking in our supply chains.
Our Effectiveness in Combating Slavery and Human Trafficking
We are committed to further developing our understanding of the issues associated with modern slavery in order to minimise the risks involved and are continuing to actively engage with our existing and new suppliers as well as further evolving our internal controls. In order to ensure our efforts are both proportionate and risk-based; we will further develop our ability to identify and differentiate between high and low risk relationships, utilising key performance indicators to measure our effectiveness and to identify any areas of potential risk at an early stage.
Following the combination of OSB and CCFS, our processes and policies are being aligned and are anticipated to be fully harmonised over the next 18 months.
This statement is reviewed annually and has been approved by the Boards of OneSavings Bank plc, Interbay ML, Ltd, Charter Court Financial Services Group plc, Charter Court Financial Services Limited and Exact Mortgage Experts Limited.
We are mindful of the current Coronavirus (COVID-19) pandemic outbreak and will report on this fully in next year’s statement. We are closely monitoring the impact of any emerging risks of slavery and human trafficking in our business and supply chains.
Chief Executive Officer
OneSavings Bank plc
Charter Court Financial Services Group plc
Charter Court Financial Services Limited
Exact Mortgage Experts Limited
Group Chief Operating Officer
Interbay ML, Ltd