Modern Slavery Statement
Remuneration Committee – Level 2
This statement sets out Al Rayan Bank’s approach to understanding all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 January 2018 to 31 December 2018 .
As part of being a Bank within the Financial Services sector, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking.
The Bank is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking. Al Rayan Bank does not invest in any business that is involved in alcohol, gambling, pornography, speculation, tobacco, arms and other activities not in keeping with the ethical values of Islam.
2. Organisational structure
Al Rayan Bank is the UK’s oldest and largest Sharia compliant retail bank. We’ve been pioneering British Islamic finance since 2004.
By solely focusing on banking activities which are in keeping with the principles and values of Islam, Al Rayan Bank is able to make a significant and lasting difference to customers throughout the UK, helping them to save for their families’ futures, expand their businesses or buy their own homes, without compromising their beliefs.
With a strategically located branch and office network throughout the UK, a highly trained contact centre, secure online banking services and 24-hour automated telephone banking, Al Rayan Bank provides Sharia compliant savings, finance and current account products to over 85,000 personal, business and premier customers.
3. Organisational Approach
The Bank’s approach for 2018 has been highlighted below:
Responsibility for the Bank’s anti-slavery initiatives:
- Policies: We operate a policy governance framework across the Bank. Each policy is owned by a Subject Matter Expert and then approved via stakeholder engagement, a sub-committee and a decision-making committee which is always at Executive Committee Level or above.
The robust Governance approach ensures the Bank gives consideration to all its responsibilities, including our Modern Slavery obligations.
- Risk assessments & due diligence: We have a dedicated Procurement function which focuses on ensuring due diligence and compliance within our supply chain. As a Living Wage employer, we have a dedicated HR team who focus on creating a culture which delivers more than our statutory obligations. All vendors to our business go through a risk assessment before we agree to work with them.
- Training: During 2019 the Bank will be asking all colleagues and contractors to complete our modern slavery eLearning module.
All colleagues are made aware of their employment rights through their employee handbook, employment contracts and our company policies. We aim to pay at market median with reference to recognised national salary surveys. The Bank is a Living Wage employer with Investors in People Silver status. All our colleagues and contractors go through our onboarding process which includes vetting their right to work in the UK and attendance at our corporate induction.
As a Bank which operates under Islamic Finance principles, we pride ourselves on providing an ethical alternative to conventional Banking. Our core values are focused on embodying our Sharia principles and having people at the heart of our business operations. We have a dedicated Sharia Compliance and Product Development team who review all of our policies to ensure we are ethical in our approach and avoid any type of exploitation of any of our stakeholders.
The Bank operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
- Whistleblowing policy: The Bank encourages all its colleagues, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the Bank. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Bank's whistleblowing procedure is designed to make it easy for colleagues to make disclosures, without fear of retaliation.
- Colleague expectations: The Bank has transparent policies and an employee handbook in place to make clear to colleagues the actions and behaviour expected of them when representing the Bank. We strive to maintain the highest standards of colleague conduct and ethical behaviour when operating and managing its supply chain.
- Procurement Policy: The Bank is committed to ensuring that its suppliers adhere to the highest standards of ethics. All vendors during the contracting process and as part of their vendor audits will be required to provide a copy of their publicly available Modern Slavery statement where they are required to have one in place under the Modern Slavery Act 2015. In addition to this all vendors will be asked to provide details of measures they have in place to comply with the said Act and how they further check their downstream supply chain are also complying with The Modern Slavery Act 2015.
During 2019 the Bank has three key areas of focus to support and build on modern slavery and Human Trafficking awareness:
- Procurement: Our Procurement team will be building on our already established foundations, including completing a full review of our supply chain and embedding our new Procurement Policy. This will include reviewing any recruitment partners we work with and ensuring they are signed up to our new recruitment agreement.
- Colleague awareness: We will be rolling out an eLearning Module and looking to support building colleague awareness on how to highlight any concerns through lunch and learns
Sharia compliance statement
The Bank operates within Sharia principles and all colleagues (*) are to be vigilant in their practices to ensure that all their actions do not conflict with Sharia principles and do not undermine these principles in any way. If staff are in doubt, then they must seek guidance from their line manager or alternatively from the Head of Sharia Compliance & Product Development. All colleagues will be responsible for reporting to their Line Manager any procedure or activities that might have an impact on the Bank’s compliance with Sharia.
The Head of Sharia Compliance & Product Development will always be included in the sign-off process for new or amended products, services and associated procedural documentation.
(*) Colleagues include anybody who is employed by, or carries out work on behalf of, the Bank including managers, officers, directors, contractors, consultants, trainees, part-time and fixed-term workers, temporary staff, agency workers and volunteers.
This statement was approved on 1 February 2019 by the organisation's Board of Directors, who review and update it annually.