Modern Slavery Statement
Atom Bank Group- Modern Slavery and Human Trafficking Statement 2023
It continues to be a priority for the Atom Bank group of companies (Atom Holdco Limited, Atom Bank plc and Atom EBT Limited) to have a zero-tolerance approach to any form of modern slavery or human trafficking, this extends to all aspects of our business and supply chain. We remain committed to acting in an ethical manner, with integrity and transparency in all business dealings.
Our Organisation and Business
We are a financial institution, regulated by the Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA), which provides financial services to customers. Our headquarters are situated in the Northeast of England, in County Durham and we have a team of 473 employees and manage £3.3bn loans, as of 31st March 2023. We do not manufacture or supply any goods.
We are dedicated to operating our business in an open, transparent, and ethical manner where all employees feel comfortable raising questions or concerns. Before starting work, all Atom employees are required to undergo pre-employment background checks. These checks include identification checks, checks for financial crime, reference checks, checks for employment eligibility, and criminal record checks. All our employees have a written contract of employment and their right to work in the UK is established prior to their employment commencing.
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We have several policies in place which reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. We continuously review and update all our policies. These include:
- Outsourcing and Third-Party Risk Management Policy
- Procurement Policy
- Whistleblowing Policy
- Vetting Policy
- Dignity at Work Policy
- Working Hours Policy
- Grievance Policy
- Anti-Bribery and Corruption Policy
- Fraud Prevention Policy
To ensure a high level of understanding of our policies we provide regular training to our staff in areas that are relevant to them.
Our Supply Chain
Our suppliers play a crucial role in supporting the provision of banking services and products to our customers. To mitigate the risk of modern slavery and human trafficking within our supply chains, we have implemented processes and controls to:
- Identify, assess, and manage potential risk areas in our supply chains.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains through appropriate governance, control, and oversight over third party providers.
- Monitor any potential risk and issues in our supply chains.
- Protect whistle-blowers.
Supplier Risk Assessment and Due Diligence
We perform appropriate and proportionate risk assessments and due diligence on our supply chain in line with our Outsourcing and Third-Party Risk Management Policy, and Procurement Policy, ensuring suppliers are able to demonstrate compliance with our policy requirements at onboarding and on an ongoing basis.
Supplier Code of Conduct
Our Supplier Code of Conduct is shared with and attested to by our suppliers. The code aims to strengthen the principles of working together and assists our suppliers in the understanding of the ethics, standards and behaviours expected when working with us. This includes requirements on complying with the provisions of the Modern Slavery Act 2015 and ensuring that the subcontractors in their supply chain also comply.
Contracting with Suppliers
Where appropriate, compliance with all applicable laws, including modern slavery, forms part of any contract that we look to put in place with key suppliers. Atom will only deal with third parties where it is satisfied the third party operates in a manner consistent with Atom’s core values.
We maintain an ongoing programme of supplier relationship management activities which includes regular monitoring of supplier performance, periodic risk assessment and due diligence to assess the suppliers control environment and identify risks and issues including but not limited to risks related to modern slavery. No concerns or issues have been identified during the 2022/2023 financial year.
Our Ongoing Commitment
We are committed to regularly reviewing and enhancing our approach to combating modern slavery and human trafficking. We will continue engaging with our suppliers to identify any ethical trading issues and incidents related to slavery or human trafficking. Should any issues be identified, we will take appropriate action.
This statement is made pursuant to s. 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year 2022/2023. Atom’s financial year ends on 31 March and this statement was approved by the Board of Directors on 14th September 2023.
LEE ROCHFORD, CHAIRMAN
20th September 2023