MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2020 Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2020 02 About Lloyds Banking Group

We are a UK financial services provider with Inside this year’s Statement around 25 million customers and a presence Modern Slavery and Human Trafficking Statement 2020 03 in nearly every community. Lloyds Banking Our Policies 04 Our Suppliers – assessing and managing risk 06 Group plc has a number of subsidiaries, Combatting modern slavery and human trafficking 08 a full list of which can be found in our Annual as a financial crime Report. Our main business activities are retail Business customers 09 Working with survivors 10 and commercial banking, general insurance Training 11 and long-term savings, provided through well Governance 11 recognised brands including , Looking ahead 12 , , MBNA and .

Our active supply base comprises approximately 3,000 suppliers, the majority of which are in professional services sectors such as management consultancy, legal, HR, IT, operations, marketing and communication.Our suppliers are located in the UK, other European countries, North America and Asia (see ‘Our Suppliers – assessing and managing risk’ for more detail). Our shares are quoted on the London and New York stock exchanges and we are one of the largest companies in the FTSE 100 index. 25m 98% 3,000 25 million customers and 98 per cent of our Our active supply base Find out more a presence in nearly every employees work in the UK comprises approximately About our Group in 2020, community 3,000 suppliers Annual Report and Accounts Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2020 03

Modern Slavery and Human Trafficking Statement 2020

This Statement outlines the This is our fifth Modern Slavery and Despite the disruption caused by Our commitment to human rights steps we have taken in the Human Trafficking Statement. It is made in Covid-19, we have continued to make accordance with section 54(1) of the UK’s progress on each of our identified A responsible and sustainable approach We are either a signatory to, or abide by, last twelve months to combat Modern Slavery Act 2015 and applies to priority areas below, even where external to doing business is central to our strategy the principles of a number of international the risk of modern slavery Lloyds Banking Group plc, its subsidiaries, limitations imposed on our colleagues and our purpose to help Britain prosper. and national codes and standards relating and human trafficking taking employees and officers of the Group and on our partners have made progress Our work to tackle modern slavery forms to responsible business practice. These place in either our business for the financial year ending 2020. slower than we would have liked. Fuller part of our wider work to embed human include: The Equator Principles, the UN This Statement was approved in February details on actions taken can be found in rights considerations into our business. Principles for Responsible Investment, the or our supply chains, and our 2021 by the Board of Lloyds Banking the sections below: UN Global Compact, the UN Universal focus areas for the year ahead. Group plc on behalf of all the Group’s We believe in the importance of doing Declaration of Human Rights, the C ontinuing to regularly review our business in ways that value and respect In 2020 we had no reported subsidiaries, and by the Boards of its International Labour Organisation’s Core principal subsidiaries Lloyds Bank plc, supplier risk assessment processes – human rights – of our colleagues, Labour Standards, the UN Environment incidents. Bank of Scotland plc and HBOS plc including piloting new tools customers, business partners and Programme Finance Initiative (UNEP FI) on behalf of the Ring Fenced Bank R aising colleague awareness of everyone that is affected by our business. Principles for Responsible Banking and sub-group. The Boards of Lloyds Bank modern slavery and human trafficking We do not tolerate slavery, trafficking or the Principles for Sustainable Insurance. Corporate Markets plc and Scottish – including introducing new training forced labour in any part of our business Widows Group Limited approved the Strengthening external partnerships or supply chains. This is reflected in how Statement on behalf of the Non Ring and collaborations – including we are embedding these considerations Fenced Bank sub-group and the collaborating with more local charities across our business. By way of example, Insurance sub-group respectively. Integrating modern slavery and human in the UK (where 98 per cent of our We do not tolerate trafficking considerations into our employees work) we have aligned our slavery, trafficking or The impact of coronavirus activities and policies with international relationships with clients – including forced labour in any The coronavirus pandemic (Covid-19) has new due diligence requirements best practice and recognised standards. created unprecedented challenges for part of our business our customers, communities, colleagues or supply chains. and suppliers. We have worked hard to protect the health, livelihoods and access to critical financial services for all of these groups. However, we are acutely aware that this pandemic may have created different risks for modern slavery, for instance, we know that it has been harder for all sectors to conduct due diligence in person. We have not relaxed our standards and the expectations we set for ourselves and our suppliers. Instead we have looked for other ways to conduct critical checks, in line with government guidance. For instance, right to work and alternative identification checks now take place online through video calls. Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2020 04 Our Policies

We have a number of internal Our policies cover a number of critical Our Colleagues We have recognition agreements with two areas including; Colleague, Sourcing, trade unions that collectively negotiate on Our Values and Behaviours are the Group policies and procedures Speak Up (whistleblowing) and Anti-Bribery. behalf of our UK workforce (around 98 per in place that reflect our guiding principles for how we work. Our 98% Each business area is required to set its cent of colleagues worldwide). The UK’s Code of Ethics and Responsibility (the commitment to operating strategy in line with our risk appetite and Living Wage Foundation has accredited We have recognition agreements Code) provides an overarching framework our policy requirements. These Group the Group as a Living Wage Employer. with two trade unions that collectively responsibly and ethically as to ensure the highest possible standards policies, associated procedures and We review our pay rates annually to ensure negotiate on behalf of our UK of behaviour and underpins our approach a business and as individual mandatory training are reviewed annually minimum rates are above the statutory workforce (around 98 per cent of to being a responsible, ethical, sustainable employees. These policies and as part of the governance of the Group’s minimum and living wage requirements colleagues worldwide) and inclusive business, for customers, Policy and Risk Management Frameworks. that are applicable in the countries we procedures help us to embed colleagues, communities, the environment This annual review reflects our efforts operate in. We have worked, and continue The Group uses a number of recruitment human rights considerations and our external stakeholders. It includes to continually improve our responsible to work, with third-party contractors agencies and service providers to fill roles. a section that outlines the ways in which into our operations. business governance approach, and to ensure that they operate in line with UK agencies are bound by contracts which respect for human rights should inform to further embed human rights into our commitments and expect them to require compliance with our Colleague colleagues’, contractors’ and temporary our business. ensure that the wages they pay meet Screening Standards and the Code of employees’ actions and decisions. legally mandated minimums without Supplier Responsibility, and which Our Human Rights Policy Statement The Code, which was updated this year, unauthorised deductions. include specific Modern Slavery and provides an overview of the work we do to encourages colleagues to report, through Anti-Bribery clauses. UK agencies also support and protect human rights within In our internal operations, our Colleague our whistleblowing service, Speak Up, attest compliance annually via the our business and communities, and is Screening Standards apply to all or to their line manager, any actions that Financial Services Supplier Qualification guided by the United Nations Guiding permanent and non-permanent are unsafe, unethical, unlawful, or not in System (FSQS). Principles on Business and Human Rights. employees that we recruit, including line with Group Policies. temporary staff and contractors. This process upholds our respect for labour rights and, for our UK employees, includes the review of individuals’ proof of identity, address, and right to work in the UK. Normally these are conducted face to face, but given the health risks of Covid-19, we have followed government advice and temporarily adjusted these checks. Since 30th March 2020, these checks are now carried out via video conference – minimising health risks, while maintaining a robust process.

Find out more Code of Ethics and Responsibility Anti-Bribery Policy Statement Human Rights Policy Statement Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2020 05

Our Policies continued

Speak up Our Suppliers R espect the human rights of their Our suppliers are also asked to comply employees and comply with all relevant with specific Third-Party Supplier Policies, Responsible sourcing is integral to the We encourage suppliers to speak up if they are concerned legislation, regulations and directives, tailored to the services they provide to way we do business. All colleagues about any actions or decisions that contravene the standards including awareness and mitigation of the Group. Third party policies such as engaged in sourcing follow the defined set out in the Code of Supplier Responsibility and we offer the risk of modern slavery in the countries Anti-Bribery, Data Privacy and Fraud, Business Sourcing Process and undertake our suppliers access to our confidential Speak Up Line and communities where they operate are documents which: sourcing in line with the requirements where they and their workers can report any incidents. including, where relevant, compliance of our Sourcing & Supply Chain An independent supplier manages the line and we have with the UK Modern Slavery Act A rticulate Lloyds Banking Group’s Management Policy. expectations in regards to behaviours worked with them to ensure that, if instances of modern Prohibit forced labour (slavery) and and decision making slavery or other human rights abuses are reported, they are We expect suppliers to meet or exceed human trafficking in their supply chain identified and effectively investigated. This formal process the provisions in our Code of Supplier A ddress the primary areas of risk which and give their employees the right is intended to be both sensitive and robust. The identity Responsibility which we share through Lloyds Banking Group faces and ability to leave employment if of those who raise a concern is not disclosed without the supplier contract as governed by our they choose T ranslate Lloyds Banking Group’s risk their permission and there is an option to raise concerns Business Sourcing Process. It defines P rohibit child labour appetite into mandatory requirements anonymously. The Speak Up Third-Party Policy has been our expectation in terms of responsible and controls designed to assist in managing any risk that Third-Party business behaviour, including human E nsure that wages meet legally Suppliers’ employees are prevented from reporting rights and labour issues in the countries mandated minimums without Our suppliers have a contractual any concerns about risk, malpractice or suspected and communities in which they operate. unauthorised deductions obligation to comply with all applicable wrongdoing. There were no reported modern We require those suppliers going through laws that apply to their supply of goods A llow their employees to exercise slavery incidents through Speak Up in 2020. the FSQS to confirm they have read, the legal right to organise and join and services to us, regardless of the understood and complied with the associations (such as labour unions) jurisdiction in which they operate. Code of Supplier Responsibility and We also include compliance with the P rovide clear and uniformly applied Code of Supplier Responsibility and provide us with evidence to demonstrate disciplinary and grievance procedures their approach. Group policies as they relate to modern including prohibiting mental, physical or slavery and standalone modern slavery We regularly review our Code of Supplier verbal abuse clauses in our supplier contracts and Responsibility to embed responsible E nsure working hours are in accordance purchase order standard terms and business and sustainability further into with local regulation and industry conditions. These clauses seek to: our business, and we commit to working practice and voluntary overtime is at facilitate termination of the contract collaboratively with our suppliers on a manageable level m anage and maintain oversight over modern slavery risks; where a supplier, or any participants developing our approach to responsible in its supply chain, are engaged in any As set out in our Group Sourcing and e nsure that we receive appropriate sourcing and sustainable procurement. practice or activity that would constitute Supply Chain Management Third Party information on suppliers’ due diligence an offence involving modern slavery. As outlined in the Code of Supplier Policy, we expect suppliers to manage procedures to monitor modern slavery Responsibility, we expect our suppliers to their own suppliers in a responsible and risks, including for its own supply chains These clauses are very rarely negotiated respect human rights, both in their own sustainable manner to mitigate supply and organisations; by Group suppliers, however, if we workforce and those in their supply chain, chain risks and to proactively work with request copies of their modern slavery encounter any supplier amendments we including to: suppliers who represent a material risk go through an escalation and sign off on such issues. For example, to mitigate statements if a supplier is required to E xplain the principles of the Code process with the business to consider the the risk that purchasing practices put report under the UK Modern Slavery of Supplier Responsibility to their risks of any supply contract, particularly undue pressure on workers in their supply Act or an annual modern slavery report employees and key sub-contractors where there is deviation from our standard chain, which can contribute to modern setting out steps the supplier has taken that support the Group or work on clauses. The clauses related to modern slavery risks, we expect suppliers to have to monitor modern slavery and ensure it our projects slavery specifically are mandatory reasonable payment policies aligned is not taking place in its own business or its supply chains; and and cannot be negotiated without Find out more to our own commitment to the Prompt legal support. Code of Supplier Responsibility Payment Code. Third Party Supplier Polices Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2020 06 Our Suppliers – assessing and managing risk

It is important that we have the tribunal in the last three years, or non- labour and human rights, and are in the compliance with the UK Modern Slavery process of a broader roll-out to targeted right framework to operate Act, Supplier Managers are required suppliers. To increase the visibility of social responsibly and before to investigate and manage through to and environmental risks in our supply selecting suppliers, we follow resolution. Where a supplier fails to meet chain we are also piloting a supplier risk a due diligence process, which the expectations set out in the Code of management tool that equips Supplier Supplier Responsibility, we commit to Managers with relevant real-time data evaluates them against key working with them to develop including media feeds of reported issues. criteria, including their human an improvement plan, however if the issue rights programmes. is deemed sufficiently serious or cannot Given the disruption caused by Covid-19, be resolved in a reasonable timeframe, we have made adjustments to how we run our due diligence of suppliers. We Lloyds Banking Group subscribes to the the Group may undertake a review of the Responsible terms of the contract, which could include have made no changes to our supplier FSQS, a third-party managed supplier management framework or our minimum qualification system for the financial triggering the right to terminate where modern slavery issues have arisen. expectations of our suppliers, so we sector that is currently used by more continue to maintain the same high Sourcing than 30 major banks, building societies The Group regularly reviews the FSQS standards, albeit how we meet these and insurance companies. This ensures risk framework. In 2019 we introduced has changed. For example, it has not We are committed to engaging with fabric and garment manufacturers we adopt a standardised approach to additional questions that trigger a ‘red been possible to conduct physical onsite suppliers to ensure that we achieve are complying with the relevant compliance and assurance, which forms flag’, prompting further investigative supplier assurance visits since March, the best value for customers - in ethical and workers’ rights standards, an integral part of our supply chain action and remediation and we are and so all reviews are being conducted terms of price and quality as well as including giving the Bank direct management. currently exploring how new technology remotely. This is part of a comprehensive social impact and we are integrating access to audits conducted by can enhance supplier managers’ use of approach to supplier management that this into our purchasing decisions. independent third-parties. We take a risk-based approach and For example, when we undertook a FSQS data, for example, to ensure that has aimed to minimise the health risks We also engage with suppliers contractually require our c.1,100 managed market review of who should supply they are focused on the most pertinent while protecting human rights across to strengthen their due diligence suppliers to self-attest their compliance the uniforms for our network branch risks associated with that supplier. our supply chain – including a process to to mitigate modern slavery risks. to the Group’s policy expectations on colleagues, a key element of our allow suppliers to work from home, where For example, as a result of our an annual basis. As part of the FSQS, The Group Sourcing Supplier Assurance evaluation methodology was to possible and without compromising discussions, the Group’s main these suppliers are asked to provide team conducts an annual programme assess suppliers according to their security, and an approach to ensure managed service provider for evidence of processes and procedures of assurance reviews for suppliers which Corporate Social Responsibility the continuity of necessary financial temporary administrative workers is for assessing and complying with relevant represent the highest risk exposure to the rating. Given the potential labour services so that vulnerable customers now affiliated with the Recruitment human rights legislation and labour Group. Suppliers that trigger agreed risk risks associated with the garment are not adversely affected. Special billing and Employment Confederation standards, including the UK Modern criteria are selected for an onsite supplier industry, it was agreed that the arrangements were put in place between (REC) who are part of the Safer Slavery Act. We require that suppliers assurance visit to test the supplier’s successful supplier must be an March and August for offshore supplier Jobs network, a joint industry and identify human rights risks such as modern adherence to relevant Group policies, established member of the Ethical staff who were not able to safely work from law enforcement organisation slavery in their supply chain and monitor which include assessment of modern Trade Initiative, which is a leading home or on site. These arrangements that works to prevent labour and assess their suppliers’ human rights slavery risks as appropriate. This year alliance of companies, trade unions allowed for a proportion of work that market exploitation, including performance. Suppliers must complete we have focused on strengthening our and NGOs that promotes respect could not be completed to be billed – on modern slavery. The provider also the FSQS questions on an annual basis, human rights due diligence processes. for workers’ rights. It was also the proviso that all such staff continued encourages agencies in their supply and employees who manage the supplier For example, we have improved the agreed with the selected supplier to be paid as normal. This approach was chain to be affiliated with REC or relationship (Supplier Managers) must human rights guidance in the supplier that they would provide auditable taken to minimise the impact on supplier Safer Jobs directly. confirm that this is satisfactorily completed assurance test plan in line with our new evidence to the Bank that their throughout the duration of the supplier’s staff in geographies where furlough or Code of Supplier Responsibility. We have equivalent schemes were not operating. contract with the Group. If a supplier also piloted a specialist third-party provides a non-compliant answer to any sustainability assessment tool with a small In 2020, there were no high priority Find out more responsible business FSQS question such selection of suppliers to provide insight on findings and no relationships exited as a Working with suppliers as the occurrence of an employment their management of issues including on result of issues with Modern Slavery. Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2020 07

Our Suppliers – assessing and managing risk continued

We have analysed our suppliers based on OUR SUPPLIER GEOGRAPHY OUR SUPPLIER SPEND geography, service sectors and spend. The majority of our direct suppliers represent a traditionally low risk of modern slavery. According to the Global Slavery Index, 99.8 per cent of our supplier spend is incorporated in geographies that are considered low risk for modern slavery; 95.3 per cent of our supplier spend is incorporated in the UK, 3.2 per cent in 82% of our external supplier other European countries, 1.3 per cent spend is in service sectors in North America and the remaining considered low risk 0.2 per cent in other countries, including India, the Philippines, Israel and Hong Kong. Additionally, 82 per cent of our external supplier spend is in service sectors considered low risk, and analysis of the remaining 18 per cent potential high risk service sectors shows that 1.3% 0.2% 95.3% Other: India, 18% 98 per cent of spend has a supplier North America of our supplier Philippines, Israel and potential high risk manager assigned, and is covered by spend is incorporated Hong Kong service sectors in the UK the FSQS. We will continue to monitor 3.2% and seek to continuously improve our Other European process of identifying risks. countries Our suppliers in India and the Philippines, 98% including IT providers, are large global of spend has a supplier firms which have undergone rigorous due manager assigned, diligence and are managed by dedicated and is covered by the FSQS Supplier Managers. Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2020 08 Combatting modern slavery and human trafficking as a financial crime

The financial sector has an The Group takes a proactive role in A sustained area of focus for the Group The Group is aware that Covid-19 may identifying potential MSHT perpetrators is on tackling the rise of child victims lead to new or increased risks of modern important role to play in the and the Group Fraud and Financial Crime of modern slavery associated with County slavery, for example by heightening fight against modern slavery Prevention’s Financial Intelligence Unit Lines drug trafficking operations in the people’s vulnerability to labour and human trafficking (MSHT), (GFIU) has made human trafficking and UK. This often involves the intimidation, exploitation. To address this, GFIU has as there may be exposure modern slavery a primary area of focus. financial exploitation and endangerment delivered training to over one-hundred The GFIU seeks to better understand of young and vulnerable people in first line colleagues in Retail and through the receipt and the MSHT threat to the Group to make smaller towns and rural areas. Transaction Monitoring to help them movement of the proceeds accurate and insightful assessments We work with the National County Lines understand these new emerging threats of crime. The Group is aware that inform our risk-based approach and Co-ordination Centre to support Group and the transactional risk indicators they of the risks and the influence response. GFIU continuously seeks to colleagues in spotting behavioural should look out for. Additionally, this obtain intelligence on MSHT to create and transactional indicators and to year, as part of Fraud and Financial Crime it can have in combatting a baseline understanding of the threat understand how these are evolving Awareness month, the Group’s Fraud modern slavery through its and its scale, and track changes over as County Lines dealers adapt to the and Financial Crime Prevention team financial crime approach time. Whilst intelligence available on coronavirus pandemic. produced a webinar on how the modern and we have implemented MSHT is limited, GFIU regularly engages slavery and human trafficking landscape with intelligence providers such as has changed in response to Covid-19. and continue to strengthen law enforcement, charities and other Open to all colleagues from across the monitoring controls to help organisations working to counter MSHT. Group, the webinar was led by subject identify activity which may be We have developed specific typologies matter experts from the anti-slavery indicative of exploitation and to identify and target financial indicators charity Hope for Justice. associated with sexual and labour proceeds relating to MSHT. exploitation and organised immigration crime and continue to innovate these in line with intelligence on the evolving nature of modern slavery. This is supported by our Group Vulnerability Strategy which includes training for The Group’s Fraud our retail colleagues on how to identify and Financial Crime suspicious activity and customers under Prevention team duress that could indicate such crimes. produced a webinar on how the modern slavery and human trafficking landscape has changed in response to Covid-19. Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2020 09 Business customers

We know that financial We regularly review all of our customers We act in accordance with the UN Global that we have a direct banking relationship Compact which includes the principles institutions, as providers of with. Where they appear to be operating that businesses should make sure that capital, have an important role outside of our risk parameters, we will they are not complicit in human rights in tackling modern slavery and work with our customers to understand abuses and should uphold the elimination human trafficking and we seek how they plan to transition to meet our of all forms of forced and compulsory risk parameters. If the customer does not labour. As outlined in our Exclusion Policy, to avoid the risk that we might transition, we will exit the relationship at we do not invest in companies identified become linked through our the earliest opportunity. We have regular as violators of the UN Global Compact business relationships to any engagements with our customers (where unless we believe we have sufficient form of modern slavery. appropriate) that we have a direct banking leverage to influence their behaviour over relationship with, and regularly review a three-year period. If companies fail to their public filings, press reports and comply with the UN Global Compact in analyst presentations. this time period, they will be excluded from the investment universe. Insurance and savings As a long-standing signatory of the UN Principles for Responsible Investment (UNPRI), we are committed to being responsible investors and stewards As a UK focused financial services Within Commercial Banking, ESG of the assets we oversee on behalf of provider, the vast majority of our assets commentary requirements have been our pension customers. The majority are in developed markets which are embedded into the credit assessment of assets held for and managed on associated with lower risks of modern process. ESG risks, including modern behalf of our customers are managed slavery. However, we know that modern slavery, must now be specifically by third party managers who comply slavery occurs all over the world, including commented upon where credit limits with our Stewardship Policy and are also in the UK, so we apply our strong risk exceed £500,000 to help inform the signatories of the UNPRI. When selecting management culture to further minimise overall credit view. During 2020 additional fund managers, we pay particular any risks. guidance has been added to Commercial attention to their abilities to identify ESG In 2020 we worked Banking internal credit policies for risks and opportunities, including human In 2020 we worked to further integrate sectors where the prevalence of low paid, to further integrate modern slavery and human trafficking rights abuses such as modern slavery, and temporary and migrant workers exposes to engage with companies they invest modern slavery and considerations into our relationships with the sector to risks of modern slavery. human trafficking clients. Our external sector statements in on important issues. We hold them to This guidance specifies the due diligence account, insisting that they demonstrate detail our expectations for corporate that relationship managers are required considerations into customers and specify that we expect that they are doing what they have our relationships to conduct including reviewing the steps committed to. them to respect human rights, both of taken by the client to ensure that there with clients. their own workforce and in their supply is no slavery in their business or its chain. We require them to comply with supply chain. applicable international conventions, sanctions and embargoes, legislation, and licensing requirements whilst showing a clear commitment to robust Find out more Environmental, Social and Governance Sector Statements (ESG) risk management. Stewardship Policy Exclusion Policy Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2020 10 Working with survivors

As the UK’s largest retail bank, Since 2017, the Group has focused on The Covid-19 pandemic has magnified helping survivors of modern slavery and existing challenges, and brought new Collaborating with others with a presence in nearly every human trafficking by mitigating two key challenges for our customers affecting community in the UK, we are banking challenges survivors face: fraud health, income, and relationships. We work with other financial service M odern slavery and human trafficking well placed to help victims of and identification. Following the introduction of government providers, NGOs, taskforces, law offences are on the rise in Northern modern slavery to rebuild restrictions, adjustments were made to enforcement agencies and key Ireland and vulnerable children are Victims’ bank accounts are often used ensure that we could continue to assist organisations to help identify and prevent often the target of gangs. For the past their lives. by gangmasters for money-laundering vulnerable customers when face to face incidences of modern slavery and human three years, The Halifax Foundation and other fraudulent activity which can appointments were not possible. trafficking. for Northern Ireland has supported As part of our Group Vulnerability prevent them from using banking services Invisible Traffick, to help raise awareness W e are a founding member and Strategy, the Group is committed to in future. To combat this, our Retail In 2020 Lloyds Banking Group has assisted about human trafficking, and to remain an active participant of the providing meaningful support across Application Fraud Team works closely 11 survivors (and a total of 61 since 2016). prevent vulnerable young children Joint Money Laundering Intelligence the range of needs of our vulnerable with recognised charities and the police This year referrals have been lower, from becoming victims. This funding Taskforce (JMLIT). The taskforce was customers, aiming to provide positive to cross-check records and documents which we understand is linked with has enabled the charity to employ an established to tackle financial crime in outcomes, and working to mitigate or in advance to ensure that fraud records the disruptions caused by Covid-19 education facilitator to visit schools partnership with the financial sector and reduce the risk of financial harm that created as a result of the activity of the – we remain committed to helping all to bring this sensitive subject into the Government and has five operational customers may face. abusers do not cause the survivors to those we are able to. classroom in a safe, non-threatening become a victim twice over. priorities, one of which is human way. The programme has been widely LBG is committed to supporting access trafficking and modern slavery. received by teachers, principals and As a result of their exploitation, survivors to mainstream banking for those who W e are partnering with the Clewer parents who have welcomed Invisible of modern slavery and trafficking may may be excluded, often due to the lack Initiative to raise awareness of a new Traffick into their classrooms and have lack standard forms of identification. of availability of standard identification tool to tackle modern slavery in farming, been encouraged by the high levels of documents, such as those who have been We have worked with a number of local 11 horticulture and food production engagement from their pupils. experiencing homelessness, victims of charities to ensure accounts can be Survivors have been in our branches. The Farm Workers modern slavery, those fleeing domestic opened for people across the UK assisted in 2020 Welfare App is designed to support abuse, or ex-offenders. by developing flexible processes. both employers and workers to spot Since testing this initiative at our Lloyds the signs of labour abuse and what We work closely with national and local Manchester Flagship branch in 2017, we charities such as Hope for Justice, Jericho to do if they suspect that workers are have expanded it to additional branch being exploited. The guidance to UK Foundation, City Hearts, Medaille Trust locations in partnership with a number 61 colleagues is that any new customer that Calling all and Crisis UK, to help those impacted of local and national charities. This year Total survivors have been by modern slavery regain their financial opens a financial product and states we also introduced a central directory assisted since 2016 that they will be working in agriculture farmers and independence and to prevent further of resources and procedures so that vulnerability to exploitation. should be given a leaflet promoting colleagues at all branches across the the Farm Workers Welfare App. Given growers… Group can assist prospective customers their heightened risk of experiencing that lack standard forms of identification. modern slavery and human trafficking, …arm yourselves and your workforce with the knowledge needed to protect any migrant worker with limited English you and them against illegal labour should also be offered worker rights providers, worker exploitation and modern slavery. leaflets from the Gangmasters and Labour Abuse Authority, even if there are no obvious behavioural signs of DOWNLOAD THE exploitation. Both leaflets are available FARM WORK in multiple languages. WELFARE APP

FREE on Google Play and iOS App stores Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2020 11 Training Governance

The Group is committed The Group’s approach to Modern slavery to raising awareness about human rights is governed is included in our modern slavery throughout the by the Responsible Business bespoke Fighting business to ensure that staff Committee, a committee of Fraud and Financial are equipped to respond to the Board of Lloyds Banking Crime training which the changing nature of this Group plc. The Committee’s is mandatory for all hidden crime. role is to support the Board UK colleagues in the in overseeing the Group’s Group to complete Modern slavery is included in our bespoke policies and performance as on an annual basis Fighting Fraud and Financial Crime training which is mandatory for all UK a responsible business. colleagues in the Group to complete on an annual basis. This was refreshed at The Group’s day to day management the end of 2019 and includes a specific of and engagement on modern slavery modern slavery case study and the ‘red and human rights is guided by a Cross- flags’ associated with modern slavery Group-wide training is further supported G roup Sourcing and Supplier Divisional Working Group, which, led by and human trafficking that will assist by targeted training for colleagues in Managers: In May 2020, colleagues Responsible Business, has input from colleagues in detecting and reporting specific roles that are more likely to from across the Group benefited from functions across the Group including HR, suspicious activity. As outlined above, encounter modern slavery. training on sustainable procurement Sourcing, Retail, Commercial Banking, as part of Fraud and Financial Crime which included labour and human Fraud and Financial Crime as well as Awareness month, the Group’s Fraud GFIU colleagues: Over one-hundred rights. In addition, Sourcing Managers external human rights experts. This Group and Financial Crime Prevention team colleagues in the Retail and Transaction completed modern slavery specific meets several times a year to assess the produced a webinar with the NGO Hope Monitoring departments participated in training in November 2020. Developed embedding of modern slavery and human for Justice to raise colleague awareness bespoke modern slavery training which in consultation with external subject rights within the Group’s operations. about the impact of Covid-19 on modern included an update on law enforcement matter experts, it covered the risks activity, investigations underway in the Other relevant committees include; the slavery and human trafficking. and indicators of modern slavery, the Group People Committee, responsible Group and the new threats that are requirements of the UK Modern Slavery emerging in the context of Covid-19 for governance of the Group’s people Act and what the Group is doing to and colleague policies, covering conduct, and the risk indicators colleagues tackle the issue. Over one-hundred should look out for. values and behaviours that can relate to colleagues participated in the session human rights concerns, as well as related Co mmunity Bank colleagues: which is available for all Sourcing and areas including remuneration and reports Induction training includes Identifying Supplier Manager colleagues to replay directly to the Chief Executive, by way and Supporting Customers in and download for future reference. of the Group Executive Committee; and Vulnerable Circumstances and annual As a result of the training 98% of the Supplier Management Governance mandatory training includes Customers respondents agree, or strongly agree, Committee responsible for overseeing in Vulnerable Circumstances. The that they understand the issue, its supplier management capability and vulnerability team have developed relevance for their role and how they delivery and is made up of representatives modules on factors that can increase are expected to respond, compared to from across the Group to embed strategy vulnerability such as domestic and 73% of respondents before the training and best practice. financial abuse, along with reworking was delivered. guidance on identification and verification to support customers lacking standard forms of identification. Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2020 12 Looking ahead

We will continue to monitor, We will continue to review and report This statement is made pursuant to the on the following indicators to assess the Modern Slavery Act 2015 and constitutes embed and evolve the way we effectiveness of our actions: Lloyds Banking Group’s Modern Slavery identify and mitigate modern and Human Trafficking Statement. slavery and human trafficking Number of colleagues trained in relation to modern slavery and Signed by risks in our business and supply trafficking: chain. This will be guided This is measured by colleague by our Human Rights Policy engagement with our annual Group- Statement, which outlines wide Fighting Fraud and Financial Robin Budenberg the Group’s position on, and Crime training module which is Chairman commitment to embed human mandatory for all UK colleagues and which, as outlined in the statement, rights considerations into our includes content on modern slavery. business operations. António Horta-Osório Looking forward, we will seek to: Group Chief Executive C ontinue to strengthen how we assess 96% and manage risk in our supply chain In 2020, 96 per cent of colleagues Raise colleague understanding of the completed training in relation to slavery risks and signs of modern slavery and and trafficking human trafficking and how to respond Strengthen external partnerships and collaborations Number of reports of modern slavery through our Speak Up line: Further integrate human rights and modern slavery considerations into our In 2020 we had no reported incidents relationships with clients of human rights breaches, slavery or trafficking. 0 incidents of modern slavery reported through Queries or comments can be our Speak Up line shared at any time by writing to: Group Chief Executive’s Office Lloyds Banking Group 25 Gresham Street London EC2V 7HN @LBGplc