Starling Bank Limited (‘Starling’ or ‘the Bank’) was founded to give people a fairer, smarter and more human alternative to the banks of the past. We are changing banking for good and that means we are committed to acting professionally, fairly and with integrity in all of our business dealings and relationships and making banking more inclusive by putting customer needs first.
We have a zero-tolerance approach to modern slavery and human trafficking and we do not tolerate modern slavery or human trafficking in our business operations or supply chains. We acknowledge that these are real, yet hidden, issues in our society and, in a time of compounding crises, are likely to rise over the coming years.
We are committed to creating and continually improving our systems and controls to prevent modern slavery and human trafficking and improving our employees’ understanding of these important issues. We also support government agencies, regulators, and law enforcement to help identify and tackle modern slavery and human trafficking in the communities and environment we operate in.
This is Starling’s second Statement on Modern Slavery and Human Trafficking, published in accordance with the Modern Slavery Act 2015. This statement refers to the financial year ended 31 March 2022 and details the approach taken to identify and prevent modern slavery and human trafficking across our business operations and supply chain.
For the year ended 31 March 2022 (the ‘year’), Starling provided banking services in the United Kingdom to 2.7 million accounts across retail and small and medium-sized enterprises, with deposits of £9.03bn.
Starling is authorised by the Prudential Regulatory Authority and regulated by the Financial Conduct Authority and the Prudential Regulatory Authority. Starling’s head office is in London, with further offices in Cardiff, Southampton, and Dublin. We have established a sustainable business model that allows us to generate our own capital organically and to expand into new markets, and have recently launched Engine by Starling, our SaaS service offering our banking platform to third parties.
Our purpose is underpinned by five Starling values: listen, keep it simple, do the right thing, own it and aim for greatness.
The Board of Directors (the Board) and the Executive Management maintain strong, open and transparent relationships with regulators, allowing the Board to ensure the Bank’s strategic aims align with regulatory requirements. Starling seeks to draw its Board and senior management team from a diverse pool with the express purpose of establishing a varied mix of skills, experience and outlook. Board members are screened for conflicts of interest and relationships with companies that do not meet our values and ethics.
Our governance framework allows for effective flow of information through appropriately structured executive committees. Key issues, including those related to human rights, modern slavery and human trafficking may therefore be raised through these channels to the Board.
We do not provide banking services or invest in organisations that use excessive power to systemically promote public behaviour that is harmful to individuals, groups or society as a whole.
Our Supply Chains
Starling is committed to developing business relationships with high quality suppliers and partners who themselves are committed to operating under ethical and environmental standards equivalent to the Bank’s own, including in the fair treatment of customers, employees and other stakeholders.
Starling utilises services from third-parties predominantly located in the United Kingdom, United States and Europe. To tackle trafficking and slavery in the supply chain we:
Incorporate anti-slavery obligations into agreements with suppliers where relevant and on a risk-assessed basis.
Adopt a risk-based approach in identifying, monitoring and assessing suppliers who are at a greater risk from instances of slavery/trafficking taking appropriate mitigating actions.
Perform due diligence and relationship oversight in line with our Supplier & Outsourcing Policy and Third Party Management Procedure, ensuring vendors meet the Bank’s expectations on an ongoing basis.
On the recommendation of the Board Risk Committee, material outsourcing decisions are made by the Board and the materiality of the Bank’s outsourcing relationships is regularly monitored. Maintaining high standards of business conduct is key to Starling and we publicly report on our payment practices and performance.
Starling does not use vendors violating labour laws.
During the year, Starling implemented processes to better measure employee engagement and enhance its understanding of the Bank’s workplace culture from an employee perspective. One process was the introduction of regular anonymous employee engagement surveys on matters such as reward and diversity and inclusion to ensure those working always have a voice.
Starling is committed to conducting its business with honesty and integrity in an open and transparent manner where all employees feel like they are able to report their concerns. Starling’s Whistleblowing Policy details the robust process that is in place to enable concerns of wrongdoing to be escalated in a confidential manner so that the necessary investigation, remediation actions and reportings and/or notification can take place. We have partnered with a charity helpline and developed an anonymised solution for employees to electronically raise any whistleblowing concerns. The Chair of the Board Audit Committee has been appointed the Whistleblowing Champion for the Bank.
All employees undergo compulsory pre-employment background checks before joining Starling to ensure they are suitable for the role they have applied for. These checks, some of which are carried out by a specialist independent screening provider, include identity checks, financial crime checks, reference checks, right to work checks, criminal record checks and, if applicable, education and professional qualification checks. Employees are also subject to annual checks, and if applicable, visa checks to ensure they remain suitable for their role.
All new hires undertake mandatory training on modern slavery and human trafficking, economic crime, conduct risk and anti-money laundering. Specialist teams, such as the risk and compliance team and customer service team, undertake additional training including on customer due diligence, complying with sanctions and fighting fraud. The customer service team is trained in identifying and supporting vulnerable customers and referring them to third party experts who can assist them. Training is compulsory and completion rates are monitored by the Bank’s Operational Risk Committee.
Starling is committed to ensuring that its employees are paid fairly and to attract and retain the best people from a diverse gender, social and ethnic background. In addition, we are a Living Wage Employer, paying our employees a wage that meets the costs of living and not just the Government minimum; therefore, all employees are paid at least the National Living Wage.
Our Customers and Partners
Starling carries out due diligence on all of its customers; personal, business and sole trader. Controls are built into its app to ensure the customer being onboarded fits within the Bank’s risk appetite. Starling adopts a proactive approach identifying suspicious activity, and where necessary takes appropriate measures for customer accounts where such activity is flagged.
Starling expects its Marketplace Partners to meet its standards. We request a copy of a modern slavery statement for our largest Marketplace Partners, both at onboarding and as part of annual due diligence reviews.
Starling has in place multiple policies to prevent modern slavery and human trafficking.
Supplier and Outsourcing Policy:
This defines the Bank’s approach to supplier management and outsourcing, to ensure that suppliers and outsourced partners meet the Bank’s expectations and comply with regulatory requirements.
Starling’s Staff Handbook and Code of Conduct:
This applies to all employees and fixed-term contractors. The Code represents Starling’s commitment to how we work and conduct ourselves at Starling. We strongly believe in acting in an ethical way and expect everyone we work with to uphold our values and principles in all that we say and do, as well as upholding all external legal and regulatory requirements and Starling’s policies and procedures.
This sets out Starling’s commitment to a culture of openness, transparency and accountability where workers feel safe to raise concerns, and to comply with whistleblowing laws and relevant regulatory expectations. The Board Audit Committee monitors the number of incidents raised through Whistleblowing channels on a quarterly basis.
We also have in place multiple financial crime compliance policies, which detail our approach to anti-money laundering, bribery and corruption, market abuse and sanctions. Towards the end of 2021, Internal Audit undertook a financial crime review which highlighted that Starling had made significant progress improving its financial crime governance framework. Starling’s dedicated financial crime team monitors and reports any suspicious activity detected using Suspicious Activity Reports to be notified to the National Crime Agency.
Starling is continually looking to improve its Modern Slavery Statement year-on year, including reviewing, and developing policies and procedures relating to modern slavery and human trafficking. The Board Ethics and Sustainability Committee will continue to receive quarterly updates on any matters related to modern slavery and will continue to escalate any issues to the Board where necessary.
We are committed to enhancing our induction and refresher training programmes, for both employees and Directors and will continue to review and develop our Policy on Modern Slavery and Human Trafficking. We will also continue to build on our relationships with our external suppliers, including ongoing monitoring of their ethics and values.
Further information on our broader approach to managing environmental and social risks can be found in our Annual Report.
This statement was approved by the Board, and signed by the Chief Executive Officer, of Starling Bank Limited on 28 September 2022 and is made pursuant to section 54(1) of the Modern Slavery Act 2015.
Chief Executive Officer
Starling Bank Limited