Modern Slavery Statement

Atom Bank plc - Modern Slavery and Human Trafficking Statement 2024

It continues to be a priority for Atom bank plc to have a zero-tolerance approach to any form of modern slavery or human trafficking, this extends to all aspects of our business and supply chain. This statement affirms that we are committed to acting in an ethical manner, with integrity and transparency in all business dealings.

Our Organisation and Business

We are a financial institution, regulated by the Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA), which provides financial services to customers. Our headquarters are situated in the Northeast of England, in County Durham and we have a team of 547 employees and manage £4.1bn loans, as of 31 March 24. We do not manufacture or supply any goods.

Our People

We are dedicated to operating our business in an open, transparent, and ethical manner where all employees feel comfortable raising questions or concerns. Before starting work, all Atom employees are required to undergo pre-employment background checks. These checks include identification checks, financial crime checks, reference checks, employment eligibility checks, and criminal record checks. All our employees have a written contract of employment and their right to work in the UK is established prior to their employment commencing.

Our Policies

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We have various policies in place that show our continuous commitment to acting ethically and with integrity in all our business relationships, as well as creating and enforcing effective systems and controls to ensure that slavery and human trafficking do not take place in our supply chains. We continuously review and update all our policies. These include:

  • Outsourcing and Third Party Risk Management Policy
  • Whistleblowing Policy
  • Vetting Policy
  • Dignity at Work Policy
  • Working Hours Policy
  • Grievance Policy
  • Anti-Bribery and Corruption Policy
  • Fraud Prevention Policy

To ensure a high level of understanding of our policies we provide mandatory training and e-learning to our staff in areas that are relevant to them.

Our Supply Chain

Our third party service providers play a crucial role in supporting the provision of banking services and products to our customers. To mitigate the risk of modern slavery and human trafficking within our supply chains, we have implemented processes and controls into our day-to-day operations to:

  • Identify, assess, and manage potential risk areas in our supply chains.
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains through appropriate governance, control, and oversight over third party providers.
  • Monitor any potential risk and issues in our supply chains.
  • Protect whistle-blowers.

Third Party Risk Assessment and Due Diligence

We perform appropriate and proportionate risk assessments and due diligence on our supply chains which are in line with our Outsourcing and Third Party Risk Management Policy, at the point of onboarding and on a periodic basis to identify any potential risks and ensure our suppliers can demonstrate compliance with our policy requirements.

Supplier Code of Conduct

Our Supplier Code of Conduct is shared with and attested to by our third party service providers. The code aims to strengthen the principles of working together and assists our suppliers in the understanding of the ethics, standards and behaviours expected when working with Atom. This includes requirements on complying with the provisions of the Modern Slavery Act 2015 and ensuring that the subcontractors in their supply chain also comply.

Contracting with Third Party Providers

Where appropriate, compliance with all applicable laws, including modern slavery, forms part of any contract that we look to put in place with material third party providers. Atom will only deal with third parties where it is satisfied the third party operates in a manner consistent with Atom’s core values.

Monitoring Third Parties

We maintain an ongoing programme of supplier relationship management activities which includes regular monitoring of performance, periodic risk assessment and due diligence and reporting to support governance and oversight to assess the adequacy of our third parties’ control environment and identify risks and issues including but not limited to risks related to modern slavery. No concerns or issues have been identified during the 2023/2024 financial year.

Our Ongoing Commitment

We are committed to regularly reviewing and enhancing our approach to combating modern slavery and human trafficking. We will continue engaging with our suppliers to identify any ethical trading issues and incidents related to slavery or human trafficking. Should any issues be identified, we will take appropriate action.

Approval

This statement is made pursuant to s. 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year 2023/2024. Atom’s financial year ends on 31 March and this statement was approved by the Board of Directors on 12 September 2024.

LEE ROCHFORD, CHAIRMAN

ATOM BANK

12 September 2024