Triodos Bank business customers are mostly small and medium sized companies that operate in the UK. 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 ) to 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.
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 the food sector, particularly in relation to the agriculture labour market when relying on outsourced workers and visa sponsored workers where malpractice is a risk; the renewable energy sector, particularly solar panel manufacturing; and the wellbeing sector, particularly healthcare and elderly care. These risks 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 solar panels manufacturers its customers work with to confirm that no human rights are being violated in their supply chain, specifically regarding forced labour by Uyghurs in China’s Xinjiang region.
The chart below shows the lending value and portfolio percentages of Triodos Bank UK Ltd across sectors as at year end 2024:
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.
Relationship managers use the information gathered through customer meetings, project visits, due diligence gathered through online searches and data-gathering tools to understand the risk factors associated with the project, including modern slavery. Although undertaken for all customers, a risk-based approach provides for a deeper focus and investigation of areas which are deemed higher risk.
We regularly review 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. If we identify anything adverse that would impact mission alignment, we engage with our customers to explore further and assess our ongoing relationship. 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 customers.
We are also committed to tackling modern slavery in relation to financial crime and the misuse of our products, services or systems by criminals. All Triodos customers are subject to due diligence processes, with customers exhibiting higher risk factors required to undergo enhanced level of due diligence and are subjected to greater scrutiny during the course of the business relationship. Customers that do not allow Triodos to comply with its legal and regulatory obligations regarding due diligence will have their banking facilities blocked and/or exited. All customer exits are managed through a robust governance process, with customers reviewed by senior management. All exit decisions are considered carefully and on an individual basis.
All customers are subject to ongoing screening against sanctions, Politically Exposed Persons and adverse media lists. Customer transactions are screened via transaction monitoring systems which create alerts for investigation by trained financial crime teams. Any activity deemed suspicious will be reported to the relevant authority, with specific codes utilised if there is suspicion of modern slavery. Triodos works closely with law enforcement authorities to support any investigation into criminal activity, including modern slavery. We recognise the need to continuously develop our co-workers and systems to effectively detect financial crime and criminal activity, including modern slavery. We are committed to further enhancing our processes to identify and flag potential higher risk indicators, as well as continuing to further educate and empower our co-workers to spot and act on the signs of modern slavery.
All co-workers undertake mandatory training on economic crime, conduct risk and anti-money laundering and have a duty to flag financial crime related issues if they see them. Our financial crime investigation team has additional skills including customer due diligence, complying with sanctions and fighting fraud.
Vulnerable customers
In line with evolving FCA regulatory requirements and guidance, principally (i) The Equality Act 2010; (ii) FCA Guidance on the Fair Treatment of Vulnerable Customers, and (iii) FCA Consumer Duty, we remain committed to ensuring that our vulnerable customers receive positive outcomes from our products and services and receive the support they need as part of our mission and values. This commitment is supported by: our Vulnerable Customer Lead within the Retail Banking department, through dedicated training, and the provision of an internal support hub so that all teams, particularly customer-facing ones, understand the needs of vulnerable customers and the potential harm when our services fail to meet those needs.
FCA research suggests that around 49% of UK financial customers display at least one of the characteristics of vulnerability, highlighting the importance of identifying and encouraging customers to disclose vulnerabilities so we can adapt our services to suit their needs. We are committed to ensuring our products and services are accessible to all customers, regardless of their challenges. Triodos Bank UK is focused on several projects through 2025 to improve support for vulnerable customers. Additionally, we recognise that vulnerability can affect our workforce as well, and we strive to identify and address instances of modern slavery or human trafficking among both customers and employees.
As an employer
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 adaptive and inclusive culture with a highly engaged co-worker community.
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. We actively encourage a culture of respectful challenge and speaking up but where issues cannot be resolved informally or co-workers would prefer a more formal approach, they can follow our Grievance Policy or our Whistleblowing Policy and use our anonymous whistleblowing hotline, Speak Up.
Training and development are provided to co-workers on many topics including technical skills, compliance matters, customer interactions, behaviours and other personal development. In November 2024, Stronger Together provided a talk to Triodos Bank UK on (i) modern slavery and prevalence as a ‘hidden’ crime today, (ii) how modern slavery might present in UK banking, and iii) how to spot the signs and escalate at Triodos. The talk was watched by 214 co-workers, who represented nearly 60% of our UK workforce at the time. A recording was made accessible to all co-workers unable to attend.
Stronger Together also conducted virtual and in-person training workshops between December 2024 and March 2025 targeting our business banking relationship managers and other co-workers most exposed to the risks of modern slavery. 45 co-workers attended this training, which included discussion of how modern slavery risks may present at Triodos, how to recognise the signs, and how to manage these risks. Through training and internal communications, we aim to educate and empower our employees to spot the signs of modern slavery and human trafficking within our supplier and customer base.
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. The hiring of temporary workers is done through a trusted and reputable recruitment agency.
Our standard terms and conditions include the requirement for the recruitment agencies we engage with to meet our supplier standards, including confirmation that they comply with all applicable laws, statutes, regulations, and codes in force relating to the UK Modern Slavery Act 2015 and any other applicable or related laws. In addition, all our agency suppliers are aware of our strict and robust candidate onboarding compliance requirements, including screening as mentioned above. We have established relationships with our agency suppliers and work in partnership to ensure a positive candidate experience.
Triodos Bank has been an accredited Real Living Wage employer since 2014, and all our co-workers are paid at least the Real Living Wage. We conduct due diligence on sub-contractors, including verification of HR procedures and research into the hourly rates paid to workers. Our forthcoming Supplier Code of Conduct will require suppliers to comply with all applicable wage laws and working hour regulations in every country where they operate, reinforcing our commitment to fair wages and working conditions. We continue to monitor compliance with legal wage requirements and engage with our suppliers to promote best practices in fair pay and the fair treatment of workers.
Our approach to third party supplier management
Triodos Bank strives for long-term collaborative relationships with our suppliers. Our 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.
The due diligence and onboarding process of suppliers commences with an understanding of the supplier category, as we know that certain sectors carry a higher probability of modern slavery. We prioritise investigations and monitoring based on risk indicators such as geography, sector, and past performance. Suppliers are required to provide information about their suitability and to provide links to their annual Modern Slavery Statements. Where necessary, suppliers are asked to provide evidence of compliance with the Act and accreditations such as SA8000 and membership to bodies such as Sedex.
Our contract management processes include specific clauses on complying with modern slavery legislation, and we maintain robust audit trails and documentation to demonstrate compliance and facilitate transparent reporting. We are in the process of establishing grievance mechanisms and clear procedures for investigating and remediating any allegations of modern slavery within our supply chain.
All procurement co-workers receive mandatory training on modern slavery, equipping them to recognise risks, interrogate supplier assurances, and escalate concerns appropriately. Training includes practical guidance on identifying modern slavery risks, due diligence procedures, and driving improvements in supplier practices.
The majority (92%) of Triodos Bank UK’s spend is focused on professional services, such as consultancy, legal counsel and membership services. These are sourced in the UK from firms that may have an international network but are accredited by professional bodies with chartered status.
The remaining spending is categorised under goods and hospitality, both of which are high-risk areas for the presence of modern slavery abuses. However, due to the strict due diligence and onboarding processes that our suppliers must undergo, we require evidence of provenance for merchandise to meet our requirements. Consumables are sourced from local suppliers, of all sizes, in line with our sustainability and diversity principles.
We are currently making progress with the development of our Supplier Code of Conduct, with anticipated completion by Q3 2025, designed to formalise our expectations of those with whom we do business. This, along with the Company Guidelines and Business Principles, will form a framework of robust standards to which we expect our suppliers to commit and demonstrate. The trinity of standards reflects our own values regarding human rights, upholding the principles of the UN Global Compact. The behaviours and the standards to which they should be held apply equally to our organisation’s activities as well as our supply chain.
Although our Minimum Standards document was designed for investment activities, and specifically for our clients’ supply chain relations, our Procurement team ensures that all potential suppliers receive a copy as part of their Tender Pack. It clarifies our position as a values-driven service provider and underlines our commitment to the United Nations’ Universal Declaration of Human Rights (UDHR). By agreeing to do business with us, the supplier is also agreeing to abide by the Minimum Standards.
Initial due diligence and regular re-assessments of the supply chain provide us with the capability to ensure that our suppliers are maintaining the standards to which we expect them to behave. We capture and review data and information on policies that encompass their own Code of Conduct and Sub-Contractor due diligence procedures, sub-contractor locations, ESG reports, labour standards policies and financial records to identify unusual patterns or anomalies. Where suppliers perform regulatory activities, the Directors are verified against agency databases to identify Politically Exposed Persons (PEPs) and any sanctions that may have been imposed on them.
We adhere to specific levels of supplier due diligence according to the criticality and value of the service; however, any anomalies found in the initial financial check that is applied to all suppliers, such as operating in countries with poor human rights, will automatically invoke an enhanced investigation. The consequence of not meeting our standards during the investigative stages could be offboarding or a Corrective Action Plan agreed.
We believe that the risk of modern slavery in our supply chain is low because the majority of services are supplied from our Group Parent company or are suppliers providing professional services or goods delivered from within the United Kingdom. We believe suppliers should be open – that’s why we strive for transparency from our suppliers. We recognise that there is still the risk of a modern slavery issue in our supply chain. These risks are scrutinised as part of the due diligence and selection processes.
Triodos Bank N.V follows a rigorous and systematic supplier due diligence and onboarding process using Hellios, an international collaborative tool for managing a single repository for supplier pre-qualification and compliance information. Hellios is an approved supplier to the bank and has been subjected to our due diligence policies and controls. Critical suppliers to Triodos Bank are required to be registered on the Hellios Platform: to be accredited they complete a detailed risk management questionnaire covering ESG, financial and ethical probity, information security, business continuity, regulatory compliance, et al covering third and fourth parties in the supply chain. The data is validated and monitored for annual re-assessment, ensuring that changes in the supply chain are assessed and risks mitigated as quickly as possible.
