Our commitments – Modern Slavery Act Transparency Statement
This statement sets out the steps that Oversea-Chinese Banking Corporation Limited (“OCBC”) has taken in relation to our responsibilities under Section 54, Part 6 of the UK Modern Slavery Act 2015 (“Act”) to mitigate the risk of slavery, servitude, forced or compulsory labour, and human trafficking (collectively “slavery and human trafficking”), within our supply chain in the financial year ending 31 December 2019.
OCBC Group provides financial products and services to individual, commercial, large corporate and institutional customers. OCBC is listed on the Singapore Exchange and the Group operates in 19 countries and regions, including the United Kingdom. We are the second largest financial services group in Southeast Asia by assets and one of the world’s most highly-rated banks, with an Aa1 rating from Moody’s.
OCBC’s stated Purpose is to help individuals and businesses across communities achieve their aspirations by providing innovative financial services that meet their needs. Our set of corporate Values – Lasting Value, Integrity, Forward-looking, Respect, and Responsibility – define the ethos and culture of our organisation, promote a common desired behaviour in the way we engage one another and our stakeholders, as well as guide us in achieving our Purpose.
Our approach to human rights is integral to and embedded within our Purpose and Values. Our ‘Integrity’ value, for example, exhorts holding ourselves to the highest ethical standards; the ‘Respect’ value requires the treatment of all stakeholders with respect and humility.
The Group upholds human rights principles to ensure that slavery and human trafficking are not taking place within our directly employed workforce as well as any of our third-party service providers and vendors. We promote best practice in our supply chain and require that all our current and prospective third-party service providers and vendors, working with and on behalf of the Group, to be conscious of our Values and act in accordance with them.
We are committed to act with integrity in all our business activities and comply with laws. Many of our existing policies contain provisions which are intended to combat slavery and human trafficking in the Group’s global supply chain.
OCBC’s current policies that address the requirements of combating slavery and human trafficking include, but are not limited to:
- Code of Conduct
- Employee Grievance Handling
- Employee Counselling and Discipline
- Outsourcing Procedures
- Whistle-Blowing Program Sub-Policy
- OCBC Group Policy on Anti-Money Laundering & Countering the Financing of Terrorism
Our relevant processes and procedures include, but are not limited to the following:
- We periodically review the effectiveness of the relevant internal policies and how these have been implemented across our business areas. Such periodic reviews are carried out to ensure that internal policies and procedures remain relevant vis-à-vis current business practices and risks.
- We have expanded our policy scope from an outsourcing policy to include third-party services (i.e. contracted services provided to the Group which includes outsourcing). The expanded scope is for the Group to keep pace with increasingly complex risks whilst relying on third-party service providers. In addition to our current Third-Party Risk Management Procedures requiring due diligence and risk assessments to be conducted on our third-party service providers, we also conduct checks and screenings on specific vendors for Anti-Money Laundering/ Combating the Financing of Terrorism (“AML/CFT”), financial stability, litigation status and conflict of interest with OCBC staff.
- We undertake due diligence on prospective third-party service providers.
- Our employees have access to the Bank’s hotline or website, both managed by an external vendor, providing an avenue for our employees to anonymously report or raise concerns or suspected unethical or corrupt behaviour.
- We expect our third-party service providers/vendors and their supply chain to share our Values, act with integrity in their business activities and comply with laws. Our employees are also expected to communicate our expectation on modern slavery to potential associated persons, or any third-party vendors.
In 2019, we made available an internal training programme to raise awareness on modern slavery. Employees will need to complete the training by 2020 and on a periodic basis thereafter. The training includes relevant examples on modern slavery and self-assessments to establish the importance of implementing and enforcing effective systems and processes to mitigate slavery and human trafficking risks within our supply chain.
This statement will be reviewed and updated annually.
Signed on behalf of OCBC Group by:
Samuel N Tsien