AIB Group p.l.c Modern Slavery Statement 2018
This statement has been published in accordance with the UK Modern Slavery Act 2015. It sets out the steps taken by AIB Group plc during year ending 31 December 2017 to prevent modern slavery and human trafficking (“Modern Slavery”) in its business and supply chains. This statement is made by AIB Group plc on behalf of AIB Group plc, Allied Irish Banks, p.l.c. and all subsidiaries of Allied Irish Banks, p.l.c. (collectively referred to as the “AIB Group”).
Introduction
AIB Group has a zero tolerance approach to Modern Slavery within its own operations and within the supply chain. We recognise the need to be aware of the risks in our business and our supply chain and have taken appropriate steps to mitigate these risks. Our Code of Conduct underpins all our actions and staff are encouraged to report any concerns which Senior Management are expected to act upon.
Our Business and Supply Chains
AIB Group operates mainly in Ireland but, through its subsidiaries, also has branches and undertakes activities in the UK. Members of the wider AIB Group operate in Northern Ireland as First Trust Bank and in Great Britain as AIB (GB). A list of the AIB Group companies, which do business in the UK, is set out in Schedule 1. As a Financial Services Business, the inherent risk of Modern Slavery in our internal operations is considered relatively low. Our supply chains are primarily confined to the Ireland and the UK, with a small number of our suppliers operating globally.
Policies
AIB Group internal policies include a Code of Conduct which sets out the key standards for behaviour and conduct that apply to all employees. The Code includes particular requirements regarding responsibilities of management for ensuring that business and support activities are carried out to the highest standards of behaviour. The application of the Code is underpinned by policies, practices and training which seek to ensure that it is understood and that all employees act in accordance with it.
We also operate a Speak Up policy which encourages staff to raise any concerns of wrong-doing through a number of channels, both internal and external, including a confidential external help-line. Employees are assured that if they raise a concern in good faith AIB Group will not tolerate victimisation or unfair treatment of the employee as a result.
Our Diversity and Inclusion policy helps us to be the best that we can in our thinking, our decisions, and our outcomes. By respecting, developing, and harnessing the talents of all our employees, we commit to creating an inclusive and supportive organisation that treats everyone with dignity and respect. We aim to respond quickly and responsibly to any complaints of discrimination, victimisation, intimidation, harassment, bullying or misconduct.
Our Outsourcing policy sets out the actions required for the implementation and subsequent monitoring of any new Outsourcing arrangement including the renewal or the alteration to any existing Outsourcing arrangement. The policy includes the requirement for a comprehensive due diligence process prior to the execution of the contract.
Due Diligence of Suppliers and Supply Chain
The largest potential exposure for Modern Slavery risk for AIB Group lies within our supply chains.
As stated above, our Outsourcing policy requires a comprehensive due diligence process prior to the execution of the contract. We have specifically addressed the issue of Modern Slavery within our terms and conditions of contract, to ensure that our suppliers are in compliance with the UK Modern Slavery Act 2015. This includes the requirement that suppliers conduct regular Modern Slavery risk assessments within their own operations and supply chains, implement appropriate controls to prevent Modern Slavery and notify AIB Group immediately if they become aware of any instances of Modern Slavery within their own operations and/or supply chains.
Assessment of Modern Slavery risk within our Supply Chain
Since 2016, we have increased our attention on the risk of Modern Slavery within our supply chain.
In 2016, we completed a risk assessment of our current suppliers focusing on geographical risk, industry/sectoral risk and the use of temporary workers. A written communication was issued to all suppliers considered by the Bank to be high/medium risk, outlining our zero tolerance approach and seeking confirmation of their compliance with applicable regulations regarding Modern Slavery (including the UK Modern Slavery Act 2015).
Modern Slavery Awareness
An awareness-raising session has been launched across AIB Group to inform staff of the UK Modern Slavery Act 2015, indicators of Modern Slavery, the actions we are taking and the consequences of getting it wrong. We have also encouraged staff to raise concerns through our “Speak Up” policy and provided external contact points.
Assessment of effectiveness in preventing Modern Slavery
Our approach to Modern Slavery risk will evolve and we will continue to mitigate this risk into the future.
This statement was approved by the Board of Allied Irish Banks, plc.
Allied Irish Banks, plc
28th June 2018
AIB Group (UK) p.l.c.
28th June 2018
SCHEDULE 1
AIB Group Companies which do Business in the UK
Aberco Limited
Allied Irish Banks, p.l.c.
AIB Group (UK) plc
AIB UK Loan Management Limited
EBS d.a.c.
First Trust Financial Planning Limited
First Trust Financial Services Limited
