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MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT Lloyds Banking Group 2019 Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2019 02 About Lloyds Banking Group We are a UK financial services provider with around 26 million customers and a presence in nearly every Modern Slavery and Human community. Lloyds Banking Group plc has a number Trafficking Statement 2019 03 of subsidiaries, a full list of which can be found in Our Policies 04 our Annual Report. Our main business activities are retail and commercial banking, general insurance Our Suppliers – assessing and managing risk 06 and long-term savings, provided through well recognised brands including Lloyds Bank, Halifax, Combatting human trafficking Bank of Scotland, MBNA and Scottish Widows. as a financial crime 08 Working with survivors 09 We employ approximately 63,000 employees (on a full-time equivalent basis), of whom 99 per cent work in the UK. Our Training 10 active supply base comprises approximately 3,100 suppliers, the majority of which are in professional services sectors such Governance 10 as management consultancy, legal, HR, IT, marketing and communication and located in the UK, other European countries, Looking ahead 11 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. 26m 99% 3,100 Find out more 26 million customers and 99 per cent of our 63,000 Our active supply base About our Group in 2019, a presence in nearly every employees work in the UK comprises approximately Annual Report and Accounts community 3,100 suppliers Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2019 03 Modern Slavery and Human Trafficking Statement 2019 This Statement outlines This is our fourth Modern Slavery and As outlined in our 2018 Statement, last We do not tolerate slavery, trafficking or Human Trafficking Statement. It is made year we focused our efforts on: forced labour in any part of our business the steps we have taken in in accordance with section 54(1) of the or supply chains. This is reflected in how the last twelve months to UK’s Modern Slavery Act 2015 and we are embedding these considerations We do not tolerate slavery, combat the risk of modern applies to Lloyds Banking Group plc, Raising awareness of across our business. By way of example, trafficking or forced labour slavery and human trafficking its subsidiaries, employees and officers modern slavery and in the UK (where 99 per cent of our in any part of our business taking place in either our of the Group for the financial year ending human trafficking employees work) we have aligned our or supply chains. 2019. This Statement was approved in 1. amongst our colleagues activities and policies with international business or our supply chains, February 2020 by the Board of Lloyds best practice and recognised standards. and our focus areas for the Banking Group plc on behalf of all the We are either a signatory to, or abide year ahead. In 2019 we had Group’s subsidiaries, and by the Boards Progressing our efforts by, the principles of a number of of its principal subsidiaries Lloyds Bank to tackle modern slavery international and national codes and no reported incidents. plc, Bank of Scotland plc and HBOS and human trafficking as standards relating to responsible plc on behalf of the Ring Fenced Bank 2. a financial crime business practice. These include: sub-group. The Boards of Lloyds Bank The Equator Principles, the UN Principles Corporate Markets plc and Scottish for Responsible Investment, the UN Widows Group Limited approved the Global Compact, the UN Universal Statement on behalf of the Non Ring Collaborating with Declaration of Human Rights, the Fenced Bank sub-group and the Insurance external stakeholders International Labour Organisation’s sub-group respectively. 3. Core Labour Standards and the UN Environment Programme Finance Initiative (UNEP FI) Principles for Regularly reviewing our Responsible Banking. supplier risk assessment 4. processes Find out more About our Group in 2019, Annual Report and Accounts Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2019 04 Our Policies We have a number of Group Alongside this statement, this year we Our Code of Responsibility (the Code) We have recognition agreements with two have made significant updates to our provides clear guidelines for doing trade unions that collectively negotiate on policies and procedures Human Rights Policy Statement. We business fairly and responsibly, in line behalf of our UK workforce (around 99 per in place that reflect our 99% have used the United Nations Guiding with our Group Values: putting customers cent of colleagues worldwide). The UK’s commitment to operating Principles on Business and Human Rights first; making a difference together; and Living Wage Foundation has accredited We have recognition agreements responsibly and ethically as to guide the development of the Policy keeping it simple. The Code encourages the Group as a Living Wage Employer. with two trade unions that collectively Statement and the Group’s broader colleagues to report, through our We review our pay rates annually to ensure negotiate on behalf of our UK a business and as individual approach to human rights. whistleblowing service, Speak Up, or minimum rates are above the statutory workforce (around 99 per cent of employees. These help us to the Group’s Colleague Conduct minimum and living wage requirements colleagues worldwide) to embed modern slavery Our policies include; Colleague, Sourcing, Management team, any actions that are that are applicable in the countries we Speak Up (whistleblowing) and Anti- considerations into our unsafe, unethical, unlawful, or not in line operate in. We have worked, and continue Bribery. Each business area is required with Group Policies. to work, with third-party contractors operations. to set its strategy in line with our risk to ensure that they operate in line with appetite and our policy requirements. In our internal operations, our Pre- our commitments and expect them to These Group policies, associated employment Vetting Policy and Group ensure that the wages they pay meet procedures and mandatory training Wide Vetting Standards, apply to legally mandated minimums without are reviewed annually as part of the all permanent and non-permanent unauthorised deductions. governance of the Group’s Policy and Risk employees that we recruit, including Management Frameworks. This annual temporary staff and contractors. The Group uses a number of recruitment review reflects our efforts to continually The Pre-employment Vetting process agencies to fill roles. UK agencies are improve our responsible business upholds our respect for labour rights bound by contracts which require governance approach, and to further and, for our UK employees, includes the compliance with our Pre-employment embed human rights into our business. review of individuals’ proof of identity, Vetting Policy and Vetting Standards and address, and right to work in the UK. the Code of Supplier Responsibility, and which include specific Modern Slavery and Anti-Bribery clauses. UK agencies also attest compliance annually via the Financial Services Supplier Qualification System (FSQS). Our Code of Responsibility provides clear guidelines for doing business fairly and responsibly, in line with our Group Values. Find out more Code of Responsibility Anti-Bribery Policy Statement Human Rights Policy Statement Lloyds Banking Group Modern Slavery and Human Trafficking Statement 2019 05 Our Policies continued Our Suppliers We expect all of our suppliers to: Our suppliers have a contractual obligation to ensure compliance with all We expect all UK suppliers to conform to Respect the human rights of their applicable laws that apply to their supply our Code of Supplier Responsibility which employees and comply with all relevant of goods and services to us, regardless of we share through the supplier contract legislation, regulations and directives, the jurisdiction in which they operate. as governed by our Business Sourcing including the Modern Slavery Act and Process. It defines our expectation in its reporting obligations in the countries We include compliance with the Code terms of responsible business behaviour, and communities where they operate of Supplier Responsibility and modern including human rights and labour issues. Prohibit forced labour (slavery) and slavery clauses in our UK supplier We require those UK suppliers going human trafficking in their supply chain contracts and purchase order standard through the FSQS to confirm they have and give their employees the right terms and conditions. These clauses read, understood and complied with and ability to leave employment if seek to manage modern slavery risks the Code of Supplier Responsibility and they choose and ensure that we receive appropriate provide us with evidence to demonstrate information on suppliers’ supply chains their approach. Prohibit child labour and organisations, including copies of Ensure that wages meet legally their modern slavery statements if they Speak Up mandated minimums without are required to report under the UK We offer our UK suppliers access to our confidential unauthorised deductions Modern Slavery Act. We go through Speak Up Line where they and their workers can report Allow their employees to exercise an escalation and sign off process with any incidents. An independent supplier, Expolink, the legal right to organise and join the business to consider the risks of any manages the line and we have worked with them to associations (such as labour unions) supply contract, particularly where there ensure that, if instances of modern slavery or other is deviation from our standard clauses. human rights abuses are reported, they are identified Provide clear and uniformly applied and effectively investigated. This formal process disciplinary and grievance procedures is intended to be both sensitive and robust. including prohibiting mental, physical There were no reported modern slavery incidents or verbal abuse through Speak Up in 2019.

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