Modern Slavery Act Statement
Slavery and Human Trafficking Statement made on behalf of Al Rayan Bank (“the Bank”) further to section 54 of the Modern Slavery Act 2015
Organisation and structure
Al Rayan Bank is the UK’s oldest and largest Sharia compliant bank, based in London, United Kingdom, with an operational centre in Birmingham, United Kingdom. Al Rayan Bank was previously known as the Islamic Bank of Britain and in 2014 it was acquired by Masraf Al Rayan, part of the MAR group of companies, one of the largest Islamic banks in the world. The acquisition joined two complementary organisations, resulting in the renaming of the Bank.
Al Rayan Bank was the first British bank to operate in accordance with Islamic principles, although the Bank employs and welcomes customers of other faiths and has become popular with non-Muslims looking for an ethical alternative to conventional banking.
Al Rayan Bank’s supply chain
The Bank has a UK-based contact centre, with highly trained customer service agents, secure online banking services and a 24-hour automated telephone banking service. The Bank’s suppliers support our functions and the retail financial services we provide to our customers. The Bank’s suppliers are subject to a risk based due diligence check before we enter into contracts with them, as well as regular ongoing risk monitoring. The majority of the Bank’s suppliers are UK based.
Our approach to slavery and human trafficking
The Bank has zero tolerance to slavery and human trafficking and is committed to taking all reasonable steps to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
Due to the nature of the Bank’s business and its supply chains, following careful consideration, we believe that the risk of the presence of slavery or human trafficking in our supply chains is low. However, the Bank is not complacent in relation to these issues.
In addition, Al Rayan Bank operates within Sharia principles and does not invest in or engage with any business that is involved in alcohol, gambling, pornography, speculation, tobacco, arms, and / or other activities not in keeping with the Bank’s ethical and Sharia principles.
Operational approach & policies in relation to slavery and human trafficking
The Bank is confident based on its core policies, risk assessments, due diligence and training, that modern slavery obligations are being met.
The Bank has defined policy management standards for application throughout the Bank. Each policy is owned by a subject matter expert and sponsored by a member of the Executive team or other Senior Managers with prescribed responsibilities under the Senior Managers & Certification Regime (SMCR). Policies are also reviewed by relevant internal stakeholders and oversight committees prior to approval at a defined decision-making committee, at Executive Committee level or above.
The Bank operates a transparent approach to its policies and has an employee handbook in place to make clear to colleagues the actions and behaviours expected of them when representing the Bank. These include the Bank’s Values, which have been defined in collaboration with colleagues and the Board. We strive to maintain the highest standards of colleague conduct and ethical behaviour in operating and managing our supply chain. The Bank’s Code of Conduct sets out standards which all colleagues are bound by. The Bank’s success is based on continuous hard work and its commitment to honesty and integrity in everything we do. We consider it vital that we conduct our banking activities with the highest standards of ethics and integrity. Specific training courses on modern slavery are also available for all colleagues to access.
The Bank’s policies include the following examples that contribute to the identification of modern slavery risks and define steps to be taken to prevent slavery and human trafficking in its operations.
- Whistleblowing Policy: The Bank encourages all its colleagues and business partners to report any concerns related to the direct activities, or the supply chains, of the Bank. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Bank's whistleblowing procedure is designed to make it easy for colleagues to make disclosures, without fear of retribution.
- Procurement & Outsourcing Policy: The Bank is committed to ensuring that its suppliers adhere to the highest standards of ethics. As part of the Bank’s supplier onboarding process, for those suppliers required to have a Modern Slavery Statement in place, we ask for evidence of their processes and procedures to demonstrate that they are complying with relevant human rights legislation and labour standards, including the UK Modern Slavery Act .
- Recruitment Policy: We use only specified, reputable employment agencies to source labour and we always verify the practices of any new agency before accepting workers from that agency.
A robust governance approach ensures the Bank considers all its responsibilities, including its Modern Slavery obligations and assesses risks as part of its approach to risk management and control.
The procurement function focuses on ensuring appropriate due diligence and compliance checks are undertaken within our supply chain by carrying out robust risk assessments before we agree to work with them.
- As a Living Wage employer, we have a dedicated HR team that focuses on creating a culture which delivers more than our statutory obligations in this regard.
- The Sharia compliance team is included in the sign-off process for new or amended products, services and associated procedural documentation, providing an additional level of oversight and challenge.
Next Steps
The Bank will continue to regularly review its approach to tackling modern slavery and human trafficking. This helps us engage with suppliers to identify any ethical trading issues and incidents of slavery or human trafficking and take appropriate action.
The Bank will continue in 2023 to focus on raising awareness of Modern Slavery wherever it deems appropriate.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Bank’s slavery and human trafficking statement for the financial year ending 31 December 2022.
The Bank’s Modern Slavery Statement was reviewed and approved by the Board on 30 March 2023.