What do we mean by Modern Slavery?
Modern slavery is a very real and present issue right now, harming some of the most vulnerable people in society.
The term covers all forms of slavery, servitude, forced labour, human trafficking and exploitation for personal or commercial gain. That includes appalling, unacceptable practices like child labour, forced marriage and sex trafficking.
Sadly, it’s all around us but often hidden from sight, as it can be difficult to spot, and many victims don’t identify that way. This makes it hard to measure the true impact, which is likely much larger than we’re aware of.
This statement shares the actions we’ve taken so far to tackle modern slavery, and our commitments on what we intend to do to help combat this offence.
- 2018’s Global Slavery Index estimated that 40.3 million people lived in modern slavery, with 24.9 million in forced labour. Measuring the impact is hard, so this number could be much higher.
- There were 7,779 modern slavery crimes recorded by UK police in the year to March 2020. That’s 59% up on the 4,897 cases recorded in the year to March 2019.
Who is Virgin Money?
We serve over 6.4 million customers across the UK through a digital-first approach. Our leading online and mobile services are supported by telephone and store banking, with a national network of stores and business banking centres. We have hubs in Glasgow and Newcastle Upon Tyne and satellite locations in Leeds, Chester and London.
We offer a full range of products and services for consumers and small and medium sized businesses, delivered through our leading technology platform to provide a consistently world class experience for customers.
We have strong historic brands that we’re bringing together as Virgin Money. We currently trade as Virgin Money, Clydesdale Bank and Yorkshire Bank; however, the Clydesdale and Yorkshire brands are being retired as we introduce customers to our refreshed Virgin Money propositions.
You can find more information on who we are and what we do on our website.
Being a Force for Good
Our ambition at Virgin Money is to drive positive social and environmental impact through everything we do to disrupt the status quo.
We’re focused on where we can make the biggest difference to the environment and society, as a purpose-led business dedicated to Making you happier about money.
As a signatory to the United Nations’ Principles for Responsible Banking, we are committed to aligning our business with the Sustainable Development Goals (and the Paris Agreement on Climate Change). In line with that commitment, we are taking steps to enable us to continually improve our impact and contribution to society and will publicly report on our progress later this year.
Human rights, fair treatment and a world free from slavery, persecution and exploitation should be a given. But they’re not, so we all need to step up and drive the change we want to see.
At Virgin Money we take this responsibility seriously. We’ve set ourselves goals and bold aspirations as part of our ESG strategy, and we’re embedding these in all areas of our business with robust targets, tracking and disclosures. An important aspect of this is managing social and environmental challenges, such as modern slavery.
Virgin Money has a zero-tolerance approach to modern slavery, and we are committed to doing business with honesty and integrity. We believe in treating everyone with dignity and respect and are committed to raising awareness and understanding of these offences to eliminate the practice from our supply chain, customer base and other stakeholder relationships.
This statement is made pursuant to the UK’s Modern Slavery Act 2015 and applies to all of our group companies (Virgin Money UK PLC and its subsidiaries) and all employees and officers of our group companies. It was approved by the boards of directors of Virgin Money UK PLC and its principle operating subsidiary Clydesdale Bank PLC on 24th March 2021.
We’re always evolving and improving how we tackle modern slavery, so we refresh this statement each year (as we are legally required to do). Up until March 2019 our Group published two separate statements, reflective of our corporate structure before the businesses of Virgin Money and Clydesdale Bank came together.
What are we doing about Modern Slavery?
Culture and Strategy
Modern slavery is firmly on our Board and Senior Management agenda, driving our zero-tolerance approach to modern slavery from the top down through all of Virgin Money.
Our goal is to consider modern slavery at every significant decision point or gateway, ensuring every colleague is empowered and committed to acting on any concerns they identify. This means incorporating the risks of modern slavery into how we assess, manage and protect customers, stakeholder relationships and suppliers.
Detect and Disrupt
We comply with the relevant laws and practices on how we should treat colleagues, customers and stakeholders (such as paying the voluntary living wage). But our role extends beyond that, to the business practices and behaviours of everyone in our entire business ecosystem.
Modern slavery could appear in our suppliers’ businesses, or further down the supply chain through the suppliers of our suppliers.
Our products and services could be used by modern slavery offenders, like slavery gangs and people traffickers.
Criminals may try to exploit our colleagues or customers in their efforts to launder their money and engage in financial crime.
It’s vital that everyone in our business knows when, where and how to look for signs of modern slavery, supported with the right processes, systems and controls to make sure we do everything possible to stamp it out for good, wherever it exists.
Policies, Process and Risk
We give our people a framework of policies, processes and technical standards to run Virgin Money safely and effectively.
There are measures and guidance designed to help us identify, assess and combat all aspects of financial crime, including money laundering, which is sometimes linked to modern slavery.
We’re committed to reviewing our Group Anti-Money Laundering & Counter Terrorist Financing Policy Standard this year to ensure we have the right controls in place for mitigating Financial Crime Risks. These controls support the mitigation of modern slavery-related offences in our operations.
We manage modern slavery risks in our customer relationships by doing our due diligence while onboarding and then refreshing the customer data we hold periodically throughout the customer lifecycle.
We monitor customer account activity to identify suspicious activity which might indicate modern slavery. Where there’s cause for concern, we make extra checks and follow the necessary reporting. This might be escalating to the National Crime Agency or the Banking Protocol – an initiative between banks, the police and trading standards which aims to identify vulnerable victims or suspicious activity, helping prevent crimes such as modern slavery. It could even be both, depending on the situation.
We work closely with external agencies and law enforcement, as well as attending industry meetings to stay on top of emerging modern slavery trends. The intelligence we get from this helps us strengthen our capabilities to recognise red flags in customers’ transactional behaviours.
We continue to monitor existing, new and emerging modern slavery risks in our business, updating and establishing new policies and processes to help us react appropriately.
Training and Awareness
We provide a suite of learning showing the knowledge, behaviours and practices that are important to a purpose-led business like ours.
Our mandatory ‘Risks in Banking’ learning is an all-encompassing online risk course educating our people on financial crime, fraud awareness, market abuse and whistleblowing.
‘Risks in Banking’ includes an anti-money laundering training module, raising awareness of all financial crime risks. We updated it this year to cover modern slavery, with guidance on spotting red flags. It includes an example of modern slavery to bring the topic to life for colleagues, before they complete an assessment at the end of the module to make sure they’ve fully understood the training. We’ll share the revised module with c.8,400 employees in spring of this year to raise awareness across our organisation of modern slavery and the ways in which we may recognise it. We review the module every year, so it stays aligned with legislative requirements and market practices, along with internal policy and process changes.
We’ve also identified several business units in Virgin Money where additional bespoke training on modern slavery is appropriate. Everyone should have knowledge and awareness of these offences, as covered in the mandatory training, but our front-line operations and risk functions play a vital role in the identification and escalation of modern slavery. We’re committed to ensuring our processes are fit for purpose, helping us create bespoke learning that best equips new and existing front-line colleagues to identify, manage and report suspicious related activity.
Suppliers and Stakeholders
We function in a responsible, ethical, open and transparent way, so it’s no surprise that we expect the same from the suppliers and stakeholders we work with. We want to ensure they uphold the same standards as we do, encouraging greater transparency within company supply chains to stamp out modern slavery-related offences.
Virgin Money has an extensive supplier base. We operate a risk-based approach to initial and ongoing due diligence which includes a review of suppliers’ ethical and social responsibility credentials. Our robust sourcing and due diligence processes are continually reviewed to ensure they are fit for purpose and reflective of current risks.
Our Supplier Code of Conduct sets out the standards, principles and behaviours we expect from our suppliers. Above all, we want to do right by our people. We protect and respect human rights and essential labour standards, including the International Labour Organisation Core Conventions. We expect our suppliers to be as committed as we are in embracing vital regulation such as the Modern Slavery Act 2015. Our top tier suppliers must positively affirm they’ve read and will comply with our code. We’re ready and waiting to work through any challenges our suppliers are facing.
Compliance relies on teamwork and, as a member of the ‘Financial Services Qualification System’ community, we’ve agreed with other banks a standardised approach to information-gathering to ensure policy compliance. We invite all our key suppliers to join this service. Currently, 180 of our suppliers share information with us as part of the system, and the level of information requested and shared by each supplier varies based on the risk classification of the products and services they provide. We use this as part of our Supplier Relationship Management process, providing oversight of each supplier’s compliance with our internal policies and governance controls.
We are also a member of Slave Free Alliance Link opens in a new window, a membership scheme for businesses to improve transparency across their supplier base. As we’ve said, compliance relies on teamwork, and we’ve been engaging with them to increase our own awareness and to understand how best we can support our supplier base.
When we work with recruitment services, we make sure our suppliers apply the same high standards that Virgin Money does. Verifying ID, the right to work in the UK, and running criminal background and credit checks helps us learn who we’re employing to identify whether someone is connected to modern slavery-related activities, as perpetrator or victim.
We want everyone to feel happier about money, but we rely on the people we work with (like our suppliers) to make it happen. We know that by working closely together with a shared purpose and values, better things are bound to follow.
We want to take the same approach to combating modern slavery as we do for delivering exceptional customer experiences that go beyond banking. That means being straight up, offering heartfelt service and staying red hot relevant.
We should always search for new ways to tackle modern slavery, and really challenge everyone we interact with to take action. That’s why we welcome the Independent Anti-Slavery Commissioner’s review within the financial services sector on ‘Preventing Modern Slavery and Human Trafficking Link opens in a new window’. We’re closely reviewing the outputs of the recommendations and will evolve our approach, aligned to these.
Modern slavery is a distressing reality. We believe it’s everyone’s responsibility to change that, and we know that Virgin Money and its people can be a positive force in that cause.
During the next year, our focus will be on educating our people, equipping them with the tools to best support the customers, businesses and suppliers we work with.
We’ve mobilized a working group focused on solving these issues and will update you later this year on our progress.
It’s vital that Virgin Money responds to modern slavery in a way that reflects our Purpose of ‘Making you happier about money’ and our values. That means being honest about the prevalence of modern slavery in our ecosystem, taking responsibility for doing something about it, and following through on those commitments.
We’re proud to report we’ve already made a good start, with initiatives such as our aspiration to ensure that by 2030 none of our customers will be paying the poverty premium. This is the extra cost that low income households pay to access basic services. We know how important it is to support and protect those that have been exploited and we must do away with the premium to remove additional burdens forced upon victims on their road to recovery. However, we know there’s still much more to do.
On behalf of the Virgin Money Board, we confirm our commitment to working with not just colleagues but also our suppliers, customers and many other stakeholders to continue to drive change and help make modern slavery a thing of the past.
Group Chief Executive Officer
For and on behalf of the boards of Virgin Money UK PLC and Clydesdale Bank PLC
24 March 2021
 Global Slavery Index 2018 (based on 2016 data), page 4 www.globalslaveryindex.org/resources Link opens in a new window
 2020 UK Annual Report on Modern Slavery, October 2020, page 8 www.gov.uk/government/publications/2020-uk-annual-report-on-modern-slavery Link opens in a new window