Allied Irish Banks, plc Modern Slavery Statement 2017

This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Allied Irish Banks, plc and the Allied Irish Banks Group during year end 31 December 2016 to prevent modern slavery and human trafficking (“Modern Slavery”) in its business and supply chains. This statement is made by Allied Irish Banks, plc on behalf of Allied Irish Banks, plc and the Allied Irish Banks Group.

Introduction

Allied Irish Banks, plc (“AIB plc”) has a zero tolerance approach to Modern Slavery within our own operations and within the supply chain. We recognise the need to be aware of the risks in our business and our supply chain and have taken appropriate steps to mitigate these risks.  Our Code of Conduct underpins all our actions and staff are encouraged to report any concerns which Senior Management are expected to act upon.

 

 

Our Business and Supply Chains

AIB plc operates mainly in Ireland but also has branches in the UK. Members of the wider AIB Group operate in Northern Ireland as First Trust Bank and in Great Britain as AIB (GB). A list of the AIB Group companies, which do business in the UK, is set out in Schedule 1. As a Financial Services Business, the inherent risk of Modern Slavery in our internal operations is considered relatively low.  Our supply chains are primarily confined to the Ireland and the UK, with a small number of our suppliers operating globally.

Policies

AIB plc internal policies include our Code of Conduct which sets out the key standards for behaviour and conduct that apply to all employees.   The Code includes particular requirements regarding responsibilities of management for ensuring that business and support activities are carried out to the highest standards of behaviour. The application of the Code of Conduct is underpinned by policies, practices and training which seek to ensure that the code is understood and that all employees act in accordance with it.

 

We also operate a Speak Up policy which encourages staff to raise any concerns of wrong-doing through a number of channels, both internal and external, including a confidential external help-line. Employees are assured that if they raise a concern in good faith AIB plc will not tolerate victimisation or unfair treatment of the employee as a result.

 

Our Diversity and Inclusion policy helps us to be the best that we can in our thinking, our decisions and our outcomes. By respecting, developing and harnessing the talents of all our employees, we commit to creating an inclusive and supportive organisation that treats everyone with dignity and respect. We aim to respond quickly and responsibly to any complaints of discrimination, victimisation, intimidation, harassment, bullying or misconduct.

 

Our Outsourcing policy sets out the actions required for the implementation and subsequent monitoring of any new Outsourcing arrangement including the renewal or the alteration to any existing Outsourcing arrangement.  The policy includes the requirement for a comprehensive due diligence process prior to the execution of the contract.

Due Diligence of Suppliers and Supply Chain

The largest potential exposure for Modern Slavery risk for AIB plc lies within our supply chains.

 

As stated above, our Outsourcing policy requires a comprehensive due diligence process prior to the execution of the contract.

 

In 2016, we have specifically addressed the issue of Modern Slavery within our terms and conditions of contract, to ensure that our suppliers are in compliance with the Modern Slavery Act. This includes the requirement that suppliers conduct regular Modern Slavery risk assessments within their own operations and supply chains, implement appropriate controls to prevent Modern Slavery and notify AIB plc immediately if they become aware of any instances of Modern Slavery within their own operations and/or supply chains.

 

 

Assessment of Modern Slavery risk within our Supply Chain

Throughout 2016 and 2017, we have increased our attention on the risk of Modern Slavery within our supply chain.

 

We have completed a risk assessment of our current suppliers focusing on geographical risk, industry/sectoral risk and the use of temporary workers.    A written communication has been issued to all suppliers considered by the Bank to be high/medium risk, outlining our zero tolerance approach and seeking confirmation of their compliance with applicable regulations regarding Modern Slavery (including the Modern Slavery Act 2015).

Modern Slavery Awareness

An awareness-raising session has been launched across AIB plc to inform staff of the Modern Slavery

Act, indicators of Modern Slavery, the actions we are taking and the consequences of getting it wrong. We have also encouraged staff to raise concerns through our “Speak Up” policy and provided external contact points.

 

 

Assessment of effectiveness in preventing Modern Slavery

Our approach to Modern Slavery risk will evolve and we will continue to mitigate this risk throughout 2017 and beyond.

This statement was approved by the Board of Allied Irish Banks, plc.

 

 

Allied Irish Banks, plc

30th June 2017

 

AIB Group (UK) p.l.c.

30th June 2017

 

SCHEDULE 1

AIB Group Companies which do Business in the UK

 

Aberco Limited

AIB p.l.c.

AIB Group (UK) p.l.c.

AIB UK Loan Management Limited

First Trust Financial Planning Limited

First Trust Financial Services Limited