Slavery & Human Trafficking

UK Modern Slavery Act 2015

The Modern Slavery Act 2015 ("the Act") of the United Kingdom requires certain businesses to provide disclosure concerning their efforts to address the issues of slavery and human trafficking in their supply chain. The disclosure is intended to assist customers with the ability to make better, more informed choices about the products and services they buy and the companies they support. 

Slavery and human trafficking refers to a variety of offences, including but not limited to: 

• Slavery, servitude and forced or compulsory labour 

• Sexual exploitation, including all offences contemplated in Part 1 of the UK Sexual Offences Act 2003 

• Removal and trafficking of organs outside the context of authorised health treatments 

• Securing services or other type of benefits by force, threats or deception 

• Securing services or other type of benefits from children and vulnerable persons. 

SMBC UK entities' stance on slavery and human trafficking 

SMBC BI, SMBCL and SMBC Nikko UK (collectively referred to as SMBC UK entities) support the SMBC Group Human Rights Report and Statement on Human Rights, based on the United Nations Guiding Principles on Business and Human Rights (UNGPs). As such, SMBC UK entities are committed to protecting and respecting human rights in accordance with international human rights standards. 

The main principle guiding SMBC UK entities' approach to slavery and human trafficking is that they should not be involved, directly or indirectly, in the commission or facilitation of the offences specified by the act. 

SMBC UK entities demonstrate an ongoing commitment to maintaining and improving systems and processes to mitigate the risk that they might be involved, wittingly or unwittingly, in the commission of slavery and human trafficking in any part of their operations, supply chain (including customers, contractors and suppliers), products, services and staff activities. 

SMBC UK entities also expects their staff, suppliers and business partners to adhere to the same high standards and to take reasonable steps to ensure that other third parties they do business with adhere to those standards as well. 

Governance 

SMBC UK entities' senior management are responsible for establishing a culture in which modern slavery is not tolerated in any form, ensuring that all staff are aware of the risks, so that informed decisions are made in a timely way, which mitigate and manage these risks. 

SMBC UK entities have established an anti-slavery policy, which sets out the processes through which they seek reasonable assurance that none of their customers, business partners, suppliers and other third parties are involved in the commission or facilitation of slavery or human trafficking. 

Risk assessment 

SMBC UK entities have conducted a risk assessment of countries, industry sectors, goods and products, which have been reported to be involved in the potential commission or facilitation of slavery and human trafficking. Specifically, the assessment of goods and industry sectors has been updated in line with the UNGPs. 

Due diligence 

All departments involved in due diligence processes are required to conduct appropriate checks in order to obtain reasonable assurance that customers, business partners, suppliers, and other third parties are not involved in the commission or facilitation of slavery and human trafficking. 

SMBC UK entities require specific anti-slavery due diligence to be undertaken on all their counterparties, and apply consistent due diligence measures for slavery and human trafficking, whereby suppliers, contractors, customers and any other business partners are all subject to the same level of identification, verification, and risk evaluation. 

In addition, in the course of conducting due diligence processes, all customers, business partners, suppliers and other third parties are subject to adverse news screening, incorporating specific terms relevant to slavery and human trafficking. 

Supply chain and customers 

SMBC UK entities expect their suppliers and customers to undertake ethical business practices, particularly in, but not limited to, economic sectors where there are higher risks of slavery and human trafficking. 

SMBC UK entities take appropriate steps to mitigate the risk that slavery and human trafficking may occur in their supply chain, or that their products and services may be used by a customer for the commission or facilitation of slavery and human trafficking. 

Any instances where it is identified that the supplier, customer, or transaction may present a heightened ESG risk, or may be involved in the commission or facilitation of the relevant offences due to their core activities, line of business, business relationships, country of establishment and/or operations, will require enhanced due diligence measures, more detailed investigation, and senior management approval. 

Employees 

In order to ensure proper understanding of the risks posed by slavery and human trafficking in the context of SMBC UK entities' supply chains and business, training is provided to employees on slavery and human trafficking and the requirements of the Act. 

Employees are encouraged to report any instances of suspected slavery and human trafficking identified in any part of SMBC UK entities' business activities. The options for raising concerns and reporting are incorporated within the 'Speak Up' framework, including internal reporting lines, and whistleblowing programme. 

It is equally important for SMBC UK entities to demonstrate that no relevant offences are committed within their premises or in relation to their own employees. Human resources have the responsibility to demonstrate, through the introduction of appropriate controls, that SMBC UK entities' own employees are being treated in line with local laws and regulations, and are not victim of any of the relevant offences as a result of their employment. 

See the Notices & Reporting page to view SMBC’s statements on slavery and human trafficking.