Position Statement Human rights
As defined by the Office of the United Nations High Commissioner for Human Rights, human rights are rights inherent to all human beings, whatever their nationality, place of residence, sex, national or ethnic origin, colour, religion, language, or any other status. All individuals are equally entitled to human rights without discrimination. These rights are all interrelated, interdependent and indivisible.
We have a responsibility to respect human rights, which is independent from the state’s duty to protect such rights. We use process, governance and due diligence to avoid infringements and complicity in the infringements of others, whether in our role as an employer, as a procurer of goods and services, or as a provider of financial services. Where we identify that we have caused or contributed to adverse impacts, we endeavour to provide or cooperate in the remediation process.
We operate in over 60 markets including many in Asia, Africa and the Middle East, giving us the opportunity to engage with a wide range of stakeholders including clients, governments, civil society and academics on human rights impacts. We are committed to playing our part in contributing to, facilitating and leading this dialogue across our markets.
Recognising the importance of human rights, we use the following standards to inform our approach to avoiding human rights infringements, and thus in developing our policies and procedures relating to staff, suppliers and business partners, and clients:
- International Bill of Human Rights, comprising:
- United Nations Universal Declaration of Human Rights
- International Covenant on Civil and Political Rights
- International Covenant on Economic, Social and Cultural Rights
- International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work
- International Labour Organisation (ILO) Conventions 138 (Minimum Age) and 182 (Worst Forms of Child Labour)
- UN Guiding Principles on Business and Human Rights (the ‘Ruggie Principles’)
- United Nations Convention on the Rights of the Child
- United Nations Global Compact
- Thun Group of Banks - The Guiding Principles: an interpretation for banks
- International Finance Corporation (IFC) Performance Standards
How we work
We uphold our commitment to respect human rights in the following ways:
We're committed to respecting the human rights of our employees. We embed this commitment through our policies and procedures including but not limited to our:
- Code of conduct, which all staff are required to commit to on an annual basis
- Speaking up policy
- Health and Safety policy
- Employment policies, including our Fair Pay Charter
- Group Employee Grievance policy
We also provide a supportive work environment including the provision for flexible working across our markets, formal employee networks and global employee guidelines for parental leave including maternity, paternity and adoption leave.
We are committed to managing the potential human rights impacts of our suppliers including within their supply chain. Our supplier charter requires suppliers to adhere to international human rights norms. We share our charter with all new suppliers, and annually with existing suppliers.
For tendered initiatives, we screen potential suppliers to ensure they have approaches in place to address modern slavery, which may include issuing a modern slavery statement. A supplier’s response forms part of our overall evaluation criteria, informing our decision on whether to do business with them.
We extend access to our independently-operated Speaking Up channel to our suppliers. Existing suppliers found non-compliant with our standards may face termination of contracts and be excluded from potential engagement opportunities.
We are committed to due diligence on human rights impacts associated with the financial services we provide. To achieve this, we have embedded controls to identify potential human rights infringements by our business clients. We only provide financial services to clients who:
- Can meet the individual human rights-related, and other, restrictions set out in our position statements. This includes considering the need for operational-level grievance mechanisms
- Where there is potential for human rights impacts to exist in clients’ operations or supply chain, provide evidence of adequate policies and processes to manage human rights risks in their operations or supply chain, in accordance with the standards referred to above
- Where required, will support the engagement of independent specialists with human rights expertise to assist in a due diligence process, for example as required under the Equator Principles. Effective due diligence may involve consultation with potentially affected groups and other relevant stakeholders
- Where there is potential for child labour in their operations or supply chain, can provide evidence of adequate policies and processes aligned to the ILO Conventions referred to above.
In addition, our policies on anti-money laundering, sanctions and anti-bribery and corruption apply to all Group offices. As one of the more serious predicate offences to money laundering and one of the most significant generators of illicit proceeds, we take fighting modern slavery as seriously as fighting drug trafficking, corruption or organised crime.
We endeavour to learn through experience, and recognise the work of the UN, OECD and others in developing guidance and tools to enable all parties to better identify and manage risks to rights-holders. As part of this, we collaborate through platforms such as the Thun Group and Institute for Human Rights and Business (IHRB), and routinely engage with civil society.
We will review this document at least every two years. We report annually on our approaches to tackling modern slavery in our Modern Slavery Statement, which provides further detail supplementing this Position Statement.
This position statement is approved by the Group Chief Executive.
Your comments are important to us and we welcome your feedback on our position statement on human rights. Please contact us at email@example.com.