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Isbank London Branch
Modern Slavery and Human Trafficking Statement – 2019
Modern Slavery is the illegal exploitation of people for personal or commercial gain. Victims are frequently trapped in involuntary servitude as a result of deception and coercion. Common forms of exploitation include human trafficking, domestic servitude, sexual exploitation, forced marriage, forced criminality and forced labour.
Section 54 of the Modern Slavery Act 2015 ("the Act") requires the publication of an annual modern slavery and human trafficking statement, including the steps taken to address modern slavery within the business and its related supply chain.
This statement applies to all Isbank London Branch ("Branch") staff and persons working on its behalf in any capacity including:
- Individuals working for the Branch or on its behalf, in any capacity, including employees at all levels, officers, agency workers, seconded workers, volunteers, interns and agents ("Branch staff"); and
- Its contractors, external consultants, agencies, third-party representatives, and business partners ("Suppliers").
Modern Slavery Policy
Isbank Turkiye Bankasi A.S. ("Isbank") is authorised by the Prudential Regulation Authority ("PRA") and regulated by the Financial Conduct Authority ("FCA") and PRA. Isbank is committed to the highest level of ethical standards and sound governance. Isbank has a zero-tolerance approach towards modern slavery and is committed to acting ethically and with integrity in all its business relationships. Isbank encourages all organisations that it engages with to influence their global supply chains by improving transparency and accountability. Isbank encourages its contractors, suppliers, and associated parties to acknowledge the mandatory requirement to comply with the Act, as far as this is possible.
Responsibility for Policy and Application
The Branch Manager has overall responsibility for ensuring that Isbank complies with the legal and ethical obligations arising under the Act. The Branch governing body, the Branch Management Committee ("BMC") has adopted this Modern Slavery policy ("Policy") and will review and approve any necessary amendments that may arise overtime.
The Branch Head of Compliance is responsible for ensuring Policy is kept up to date based on any business changes concerning the Branch and or underlying legislation.
Branch Management is responsible for implementation and ensuring that those reporting to them understand and comply with Policy.
Policy will be reviewed at least on an annual basis, by the BMC. The Branch risk management structure provides the necessary framework to support ongoing compliance with the requirements of the Act, primarily through Compliance monitoring and oversight, including the review of processes in place for implementation; monitoring their use and effectiveness; and ensuring that managers and employees have received adequate training, as appropriate.
The Branch maintains a Suppliers List in support of meeting Supplier due diligence obligations, including whether each Supplier has an adequate policy and or statement in place to tackle modern slavery. The Supplier List is maintained by Branch Operations Department which is responsible for undertaking adequate Supplier due diligence consistent with Policy.
Compliance with Policy
All Branch staff must ensure that they read, understand and comply with Policy and attest as such, to the Head of Compliance, at least on an annual basis.
All Branch staff and Suppliers are required to ensure that they avoid any activity that might lead to, or suggest, a breach of Policy. Any doubts as to whether such activity contravenes Policy, should be referred to the Branch Compliance Officer on a timely basis.
The Branch will only employ individuals who are legally permitted to work in the UK, as evidenced by valid documentation and related checks undertaken as part of employment procedure. The Branch will always adhere to minimum wage obligations under the relevant UK national minimum wage legislation.
Isbank encourages openness and transparency and will support anyone who raises genuine concerns in good faith under Policy. As per the Branch Whistleblowing policy, those who raise concerns, even if these concerns result in no action, will not suffer any detrimental treatment. All notifications under Policy will remain confidential. Detrimental treatment in this case means disciplinary action, dismissal, threats or any other unfavourable treatment that results from raising a concern. Any detrimental treatment should be reported in accordance with Branch Whistleblowing policy.
Communication and Awareness of Policy
The Branch will provide appropriate staff training within respect to obligations arising under the Act through an online training and assessment module and at least on an annually basis. In addition, this Statement and Policy will be readily accessible to all staff through Policy Hub, the Branch's online management information system. As already noted above, all Branch staff will be required to provide an annual attestation as to their compliance with Policy.
Breaches of Policy
Any member of staff who is in breach of Policy may face disciplinary action which could result in dismissal for misconduct or gross misconduct. Isbank may terminate its relationship with other individuals and associated parties working on its behalf, if they are found to have breached Policy.