This statement has been published in accordance with Section 54 of the UK Modern Slavery Act 2015 (the Act). The Act requires businesses to publish a statement setting out the steps they have taken to prevent modern slavery in their business and supply chains. 

This statement outlines the steps taken by Starling Bank Limited (SBL) and Starling FS Services Limited (SFFSL). We refer to the two companies together as Starling, we, and our. The statement is for the financial year ended 31 March 2025 (the year). It is a joint statement covering these two companies, as they both meet the requirements to publish a modern slavery statement under the Act.

Our structure

During the year SBL provided banking services to 4.6 million people and businesses across the UK. We held £12.1bn in deposits for our customers in that time. Meanwhile, SFSSL, a wholly owned subsidiary of SBL, focused on the design, specification, build, test and implementation of software. This software supports the mobile banking platform. We have offices in:

Starling’s governance framework allows for the effective flow of information. Our structure of committees at board and executive level allow key issues to be raised with our Board of Directors (the Board). These issues include:

Our governance framework is key to our approach to overseeing modern slavery risks in Starling’s operations and supply chain. The policies and due diligence procedures described in this statement apply across Starling.

Our business

Starling was founded to give people a fairer, smarter and more human alternative to the banks of the past. Starling’s continued digital banking innovation drives it forward and bridges the gap between the customer, their finances and technology. Starling wants to use technology and a human-centric approach to help customers gain active control of their finances through effortless everyday habits. We are committed to acting professionally, fairly and with integrity in all of our business dealings and relationships. 

We have created a sustainable business model. We aim to drive consistent profitable growth and generate capital - all while making ourselves more resilient to the wider economic environment. Starling’s vision and mission are underpinned by five cultural values embodied by the directors, management and employees:

These values drive our strategy and are integrated across all functions at Starling. Our Code of Conduct reiterates and embeds Starling’s values. It applies to all directors, employees and agency staff. 

Starling has a zero-tolerance approach to modern slavery and human trafficking. We do not tolerate any form of slavery or human trafficking in our business operations or supply chains. We acknowledge that these are real but hidden issues in society. 

Starling is committed to protecting human rights and preventing modern slavery and human trafficking. We do this by creating and continuously improving our systems and controls. We also improve our employees’ understanding of these important issues.

We take a proactive approach by:

Our supply chains

Starling’s supplier base includes the following broad categories: 

We are committed to working with high quality suppliers who share ethical standards and values aligned with Starling’s Ethics Statement. This includes treating customers, employees and other stakeholders fairly. Starling takes a risk-based approach in identifying, monitoring and assessing suppliers. 

We manage the risk of trafficking and slavery in the supply chain by:

The SBL Board (supported by the SBL Board Risk Committee) sets the control environment for the firm. This includes the risk appetite and tolerance levels for outsourcing and third party risk management.

Maintaining high standards of business conduct is crucial to Starling. We monitor our outsourcing relationships closely. We recognise that prompt payment is essential to the cash flow of businesses of all sizes. It helps make sure workers are paid on time and reduces the risk of exploitation. SBL’s payment practices and performance are publicly reported on, per statute. In 2025, SBL was awarded Gold at the Office of Small Business Commissioner’s Fair Payment Code Awards. This was for paying at least 95% of suppliers’ invoices within 30 days.

Our people and their training

Starling has over 3,500 employees (all employed by SBL). We are committed to providing a workplace culture that is:

Our employees should feel safe to raise concerns about Starling’s operations without fear. This culture is supported by Starling’s Whistleblowing Policy. This details our robust confidential processes for escalating concerns of wrongdoing, including modern slavery. Additionally, it allows investigation, remediation, and notifications to take place. Starling is committed to conducting business with honesty and integrity. We expect all employees to maintain high standards in accordance with policies and procedures. You can read more about Starling’s Whistleblowing Policy in the ‘Our Policies’ section below. 

We have an open approach to employee engagement. We run regular, anonymous surveys to ensure employees have a voice. Key themes arising from the results of these surveys are discussed with the SBL Board. 

All employees undergo compulsory pre-employment background checks before joining Starling. These checks can spot signs that an individual may be a victim or perpetrator of modern slavery or human trafficking. We use a specialist independent screening provider for some of these checks. These include identity, financial crime, referencing, right to work, and criminal record checks. Employees are also subject to checks periodically during their employment.

Starling recognises the importance of training to ensure our employees are able to identify the signs of modern slavery. They are then able to act on them appropriately. All new employees undertake mandatory training on the following topics, and refresh their knowledge every year:

Specialist teams, such as the Risk, Compliance, and Customer Service teams, undertake additional training. This includes topics such as customer due diligence, complying with sanctions and fighting fraud. Completion rates are monitored by SBL’s Operational Risk Committee. The Customer Service team is trained in identifying and supporting vulnerable customers. They can then refer them to third-party experts for assistance. 

The e-learning materials for modern slavery and human trafficking were enhanced during the year. Guidance on handling exploitation, safeguarding and reporting was also rolled out across Starling. Management at all levels are responsible for ensuring those reporting to them understand and are given adequate and regular training on the issue of modern slavery and human trafficking in supply chains.

We are an equal opportunities employer. We give fair and full consideration to employment applicants regardless of their age, gender, ethnicity, race or disability. Starling is proud to be an accredited Living Wage employer. We ensure our employees are paid fairly, whilst aiming to attract and retain the best people with diverse mindsets, experiences and skills. You can read more about Starling’s Staff Handbook and Code of Conduct in the ‘Our Policies’ section below.

Our external engagement

Starling is continuously working to develop the effectiveness of our risk and control framework. This strengthens Starling’s ability to detect, disrupt, and prevent the exploitation of our customers and the wider public. Here are some examples of how we are doing this:

In October 2024, we partnered with an anti-slavery charity. This partnership allowed us to hold an awareness session for our employees. The session explored how modern slavery impacts everyone. It also highlighted that modern slavery is often nearer to individuals’ daily lives than they might expect.

Our customers

At Starling, we’re committed to:

Starling carries out due diligence on all customers; personal, business and sole trader. We’ve also built controls into our app to make sure customers are not involved in financial crime. This includes modern slavery and human trafficking. 

Starling takes a proactive approach to identifying suspicious activity. We take appropriate measures when suspicious activity is flagged. Starling has invested heavily in capability, capacity and technology to detect and prevent financial crime. We continue to actively engage with relevant oversight bodies, including industry groups. We seek to ensure that relevant information for the detection and prevention of financial crime is shared in a timely manner.

Economic and financial abuse are forms of control used by offenders during the exploitation of modern slavery victims. As a Financial Abuse Code Signatory, we train and guide all our customer-facing employees to recognise and respond to signs of these types of abuse. For more complex and sensitive cases, we have a dedicated Welfare Support team. This team is able to adapt our services for victim-survivors and refer them to specialist organisations, in line with their needs. 

We’ve also introduced language translation to support our customers. This makes it easier for them to communicate and share information with Starling directly when they need support. 

We have enhanced key metrics. This helps to better understand Starling’s exposure to modern slavery and human trafficking risks, from both a victim and perpetrator perspective. This also strengthens our monitoring approach. Moreover, we have built assessments into the Disclosures team’s activities. This is to ensure that reporting data and glossary codes are tracked effectively. 

Our policies

The following policies support our commitment to preventing modern slavery and human trafficking in our supply chains. They are reviewed annually and signed off by the Board.

These key policies are supported by the following internal documents:

Looking ahead

We will keep working to improve Starling’s modern slavery controls in the workplace. This includes reviewing and updating our policies and procedures on modern slavery and human trafficking, particularly in light of business growth and expansion. 

The SBL Executive Committee will receive updates on matters related to modern slavery. It may escalate issues to the SBL Board. It will do this where relevant triggers and limits are met. This will be via our Board Risk Committee.

We are also committed to developing our employees’ understanding of modern slavery and human trafficking. We will continue to provide tailored information through our induction and refresher training. This will apply to directors too. Our Intelligence Unit will continue to support and supplement our training efforts. They will run Starling-wide sessions on the importance of tackling modern slavery and human trafficking. We will also partner with leading organisations to raise awareness around key dates. This includes Anti Slavery Day in October 2025.

Starling will keep strengthening relationships with our suppliers. We will continue to engage with them on matters around modern slavery and human trafficking. We will also make sure their ethics and values meet Starling’s expectations.

You can read more about Starling’s broader approach to managing environmental and social risks here: https://www.starlingbank.com/investors/2025/annual-report-2025/.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015. On 23 September 2025, it was approved by, and signed on behalf of, the Board of Starling Bank Limited and the Board of Starling FS Services Limited.

Raman Bhatia

Director

Starling Bank Limited

¹ The signature of Starling FS Services Limited on the annual statement made pursuant to the Modern Slavery Act 2015 is available on request from Company Secretariat, Starling Bank Limited, 5th Floor, London Fruit and Wool Exchange, 1 Duval Square, E1 6PW.