Triodos Bank business customers are mostly small and medium sized companies that operate in the UK, where we have relatively strong regulatory frameworks regarding human rights. As a leading ethical bank in the UK, we exist to only finance and invest in companies, institutions and projects that support positive social, cultural or environmental change. We believe banks should be open – that’s why we publish details of every organisation we lend to on our website (www.knowwhereyourmoneygoes.co.uk) and offer complete transparency.
We assess our lending, finance and investment decisions according to our own social criteria and according to those detailed in relevant international standards and guidelines (where applicable). These include the UN Global Compact, OECD Guidelines for multinational enterprises and the Equator Principles. We apply these proportionally, based on the type of customer, their size and activities.
As part of our due diligence, we have identified the human rights most at risk in our role as a lender and financier, as an employer and as a contractor. Triodos Bank has held internal consultations with relevant stakeholders in our banking business, human resources and procurement departments to identify any salient issues.
Despite the exclusions put in place by our Minimum Standards, we recognise that there is still the risk of potential human rights issues in our lending business, for example in the supply chains of our customers. We’ve identified areas where the risk is most prevalent, including farming, particularly in relation to seasonal workers; renewable energy, particularly solar panel manufacturing; also in the consumer sector, and these are scrutinised as part of the due diligence and selection process we undertake on our banking customers. For example, in relation to solar panels Triodos has asked all customers to confirm that no human rights are being violated in their supply chain, specifically regarding forced labor by Uyghurs in China’s Xinjiang region.
Our team of relationship managers determine the positive and negative social, environmental and cultural impact of each (potential) customer. They engage intensively – often face to face - with customers and require relevant information to determine impact (if relevant, also relating to human rights). To assess credit and investment proposals, our relationship managers and fund managers refer to our Business Principles in the first instance. Then, the Lending Criteria which specify how Triodos Bank’s vision and mission are translated into banking practice are applied.
Every year we review all our lending customers in business banking to determine if they still match our mission and values, in line with our Business Principles and Minimum Standards. In the case of relevant developments, we engage with our customers. Of course, our relationship managers are in regular contact with customers during the year. If issues arise before or after the formal review, they will address them with their customer.
In 2022 we will provide bespoke training and support to the relevant co-workers by rolling out training on how to identify indicators of modern slavery, based on intelligence from the national Financial Intelligence Unit. This training will be delivered in partnership an organisation that specialises in tackling modern slavery.
We are committed to tackle modern slavery in relation to financial crime and the misuse of our products, services or systems by criminals. In line with our regulatory obligations, we have a financial crime team made up of subject matter experts, which will investigate any suspicious activity or risks and have strict anti-money laundering measures are in place. We will always collaborate with the government, NGOs and law enforcement to help identify and mitigate against modern slavery or criminal activity. We end relationships with customers if there are indicators or concerns and report it to the authorities (National Crime Agency).
Our risk and compliance team and customer service team have additional skills including on customer due diligence, complying with sanctions and fighting fraud. Enhanced support for Vulnerable Customers, in line with FCA guidance, is achieved through ongoing delivery of specific training, and appointed customer vulnerability specialists within the customer contact team. All co-workers undertake mandatory training on economic crime, conduct risk and anti-money laundering, as well as how to be inclusive in relation to vulnerable customers.
The Bank’s mission has human dignity and quality of life central to all that we do, and this is integral to how we support our co-workers to achieve success. Our people strategy is designed to support our mission, enabling our co-workers to create positive social, cultural and environmental impact by creating an environment in which co-workers can thrive as a diverse, healthy and resilient community delivering sustainable high performance.
We believe everyone has the right to work in a safe and supportive environment. We aim to foster an open and transparent workplace where each individual acts in line with our values and feels comfortable to raise concerns when they think something is wrong, by following our whistleblowing policy or using our anonymous whistleblowing hotline, Speak Up.
Training and development are provided to co-workers on this and many other topics including technical skills, customer interactions, policies and personal development. For more information, read our Co-worker report in our Annual Report.
All co-workers, temporary workers and contractors undergo rigorous pre-employment screening before joining Triodos and this includes adequate checks that they have the right to work in the UK.
We are committed to creating a welcoming and inclusive work environment and to identifying potential barriers to entry to the organisation. We use contextual recruitment software which enables us to consider applicants’ achievements in the context in which they were gained because we understand that not everyone’s achievements look the same on paper and we want to recruit the best people, from every background. We are also entering the third year of our internship scheme, hosting a diverse range of students from the University of the West of England and the University of Winchester.
Equity, Diversity and Inclusion (EDI) continued to be an important focus during 2021 in which creating a co-worker population representative of our customers and communities remained a priority. Triodos Bank UK benchmarks itself against local and national data, aiming to attract and recruit individuals from underrepresented sectors of the communities in which we operate. EDI training for all Triodos Bank UK co-workers became a mandatory requirement in 2021 and we saw the establishment of an active Inclusion Forum. Further details on our work in this area can be found in our diversity and inclusion statement.
Triodos Bank has been an accredited Living Wage employer since 2014 and all our co-workers are paid at least the Real Living Wage. We also require all those employed via suppliers and contractors operating on site (e.g. cleaning staff) to be paid the Real Living Wage. We undertake an annual payroll audit to ensure this is adhered to. Our total reward package includes a defined contribution pension scheme with non-contributory employer contributions of up to 10% salary, private medical insurance, income protection and life assurance.
We also have a 24/7 employee assistance and wellness programme, designed to support coworkers experiencing mental health issues or other challenges impacting them for example relationships, bereavement, or financial concerns. In 2021 we launched a continuous listening platform where we invite co-workers to complete regular surveys telling us what it’s like to work at Triodos and sharing their views on how we can work together to continue to improve things for co-workers and our customers.
As stated in our Business Principles, the environmental and social considerations underpinning our procurement activity are translated into the Triodos Bank Procurement and Vendor Management policies. Sustainable procurement combines these aspects with the standard focus on value for money when buying goods or services.
Most of our suppliers are small and medium sized companies. We closely monitor for human rights issues with these suppliers. We also have contracts with larger organisations. Through their activities and supply chains there is a risk we can be linked to potential negative human rights impacts, especially when supply chains are in regions with relatively weak regulation and enforcement. We have identified the extraction of raw materials for ICT appliances as a salient issue in our supply chain, amongst other categories of spend such as recruitment, catering and cleaning.
Triodos Bank strives for long-term collaborative relationships with our suppliers. Our Procurement, Vendor Management and Outsourcing policies outline our ambition to work in partnership with suppliers to align our positive impact ambitions and promote the use and adoption of more sustainable products, production processes, and supply chains. All suppliers we work with therefore go through a rigorous onboarding process and are then re-assessed at regular intervals. Modern Slavery is considered across our suite of vendor management processes, governance, and inhouse procurement training.
Triodos Bank aims to get all of our suppliers to sign our company guidelines, including our Business Principles, which apply to our own organisation and to those doing business with us. Triodos also regularly re-assesses the suppliers fit to Triodos. Through our sustainable procurement policy, which is applicable to all our suppliers, they are expected to comply with the same principles regarding human rights we have adopted for our own activities.
We assess our strategic suppliers through dialogue according to our Minimum Standards and strive to implement this way of working for all our suppliers. In addition, we consider international standards and guidelines that support sustainable development, such as the latest Global Reporting Initiative guidelines. Where appropriate we provide feedback to suppliers about their own environmental and social performance.
Given our size and close relationship with our customers and their natural focus on ethical values, we believe that the risk of modern slavery in our operations and our supply chain are low. However, we will not be complacent, and we know there is more that we can do.
In 2022, we will increase our training, and strengthen our processes where necessary. We will raise awareness of modern slavery and human trafficking with all Triodos Bank UK co-workers by hosting all-staff meetings on the topic and publishing content on the Bank’s intranet on the steps we take to tackle modern slavery and the impact it has on victims. We will take a zero-tolerance policy to modern slavery and human trafficking and are committed to continuing to strengthen our processes and raising the focus on this issue, by ensuring we understand the signs to look out for and how to offer support when needed.
This statement was approved by the Board of Triodos Bank UK Ltd on 15 June 2022.
