Our commitments – Modern Slavery Act Transparency Statement
This statement sets out the steps that Oversea-Chinese Banking Corporation Limited (“OCBC”) and our owned and controlled subsidiaries have taken in relation to our responsibilities under both the UK Modern Slavery Act 2015 (the “UK Act”) and the Australian Modern Slavery Act 2018 (Cth) (the “Australian Act”) to mitigate the risk of modern slavery taking place in our operations and our supply chain in the financial year ending 31 December 2022. We conduct our business in the UK through our London branch (registered in England No. BR000981), and in Australia through our Sydney branch (registered foreign company No. ARBN 073 598 035).
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 have been a signatory to the United Nations Global Compact (UNGC) since April 2008 and observe its ten principles in the areas of human rights, labour, the environment and anti-corruption. 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 structure, operations, and supply chains
OCBC is the longest established Singapore bank, formed in 1932 from the merger of three local banks, the oldest of which was founded in 1912. We are now 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. Recognised for its financial strength and stability, OCBC is consistently ranked among the World’s Top 50 Safest Banks by Global Finance and has been named Best Managed Bank in Singapore by The Asian Banker.
OCBC’s key markets are Singapore, Malaysia, Indonesia and Greater China. It has more than 420 branches and representative offices in 19 countries and regions. These include over 190 branches and offices in Indonesia under subsidiary Bank OCBC NISP, and over 60 branches and offices in Mainland China, Hong Kong SAR and Macau SAR under OCBC Wing Hang Bank.
Our business strategy focuses on three core businesses of Banking, Wealth Management and Insurance.
OCBC Group offers a broad array of commercial banking, specialist financial and wealth management services, ranging from consumer, corporate, investment, private and transaction banking to treasury, insurance, asset management and stockbroking services.
Our private banking services are provided by our wholly-owned subsidiary, Bank of Singapore, which operates on a unique open-architecture product platform to source for the best-in-class products to meet its clients’ investment needs.
Our insurance subsidiary, Great Eastern Holdings, is the oldest and most established life insurance group in Singapore and Malaysia. Its asset management subsidiary, Lion Global Investors, is one of the largest private sector asset management companies in Southeast Asia.
OCBC Group’s business in all our locations is office-based. The business activities undertaken by OCBC and the entities it owns or controls are supported by a network of suppliers providing goods and services, such as office supplies, computer systems, software applications, document management, professional services, financial services and other outsourced operations.
Risks of modern slavery practices within operations and supply chains
Modern slavery is a global issue and can take various forms including forced labour, child labour, slavery, human trafficking and other exploitative practices. These issues have particular relevance to banks, as financial intermediaries and capital raising agents, in promoting economic development. We recognise that the risks may be inherent and more pronounced in certain industry sectors and geographies and seek to integrate the relevant risk considerations into our business and risk management practices. We will continually enhance our processes and practices to align with the international frameworks and relevant developments in the jurisdictions in which we operate.
As part of OCBC’s branch network, OCBC Sydney Branch has been complying with relevant internal policies and procedures. Following the implementation of the Australian Act, OCBC Sydney Branch has taken further steps to identify the risk of modern slavery practices in its operations and supply chain, primarily having regard to the sector and geographic origin of the products and services it acquires. OCBC Sydney Branch identified that suppliers who fall into the higher risk industries for modern slavery include electronics, stationery, storage services, cleaning services, security services, repairs and maintenance and courier services. Given that OCBC is a financial institution, its Sydney Branch’s employees are either finance professionals or administrative support staff. Therefore, the risk of modern slavery practices within its own operations is considered low.
Actions taken to assess and address modern slavery practices
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;
- Third-Party Risk Management Procedures;
- Whistle-Blowing Programme Sub-Policy; and
- 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:
- The public and our employees have access to the Bank’s whistleblowing hotline and website, both of which are managed by an external vendor to provide an avenue for our employees to anonymously report or raise concerns on 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 service providers or vendors.
- Our Third-Party Risk Management Procedure sets out due diligence to be conducted on our prospective and current outsourced and third-party service providers.We regularly measure the level of employee engagement using a model by an external consultant that specialises in the area of human capital management.
Employees are required to complete an internal staff training programme to raise awareness on modern slavery, including completing a refresher training once every two years to keep abreast of the latest developments and obligations to combat modern slavery. 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.
Measuring effectiveness of actions
OCBC is cognisant of the importance of identifying and addressing the bank’s modern slavery risks. We are committed to build upon our frameworks and processes to ensure we can review the effectiveness of actions taken to assess and address modern slavery risks in our operations and supply chains.
As such, 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, and that best practices are gradually implemented where appropriate. We also conduct biennial employee engagement surveys, managed by an external vendor, to assess the level of employee engagement. The employee engagement score (71% for the last employee engagement survey conducted in 2021) serves as an indicator of the effectiveness of our actions taken to mitigate modern slavery risks.
Additionally, we perform ongoing due diligence reviews on our current outsourced and third-party service providers, which includes addressing the modern slavery risk in our supply chains.
This statement is the result of a collaborative effort between the key stakeholders within the OCBC Group.
This statement is updated and approved by our Board of Directors annually.
Signed on behalf of OCBC Group by: