1. Overview

At Starling we have a zero-tolerance stance towards slavery and trafficking. We are committed to protecting human rights and preventing modern slavery and human trafficking by creating and improving our systems and controls. This is Starling’s first modern slavery statement. It explains what we have done so far; what measures we have in place to prevent it; and next steps. As we develop our plans further, we will update this statement too.

2. About us

Starling Bank Limited is a fully-licensed and regulated digital bank incorporated in England Wales. We are based in the UK and also have an office in Dublin.

We have over 1600 employees across the UK in Cardiff, Southampton, and London.

More information on our organisational structure, corporate governance and accounts can be found in our annual report 2019/21.

This statement is applicable to Starling Bank Limited and its Group subsidiaries which include Starling FS Services Limited and Murmur Financial Services International DAC.

3. Our policies on modern slavery and human trafficking, due diligence and risk management

We are committed to preventing modern slavery or human trafficking in our business and our supply chains. For us, good business and ethics go hand in hand. Our ethics statement can be read here.

Our current policies are:

  • Our people. We are committed to a workplace culture that reflects our values of fairness, compassion and non-discrimination. Our staff is recruited legally, and we comply with the Immigration Act 1998. We have a whistleblowing policy in place and a whistleblowing champion.
  • Our customers. To ensure our customers are protected against modern slavery:
    • We assess our business customers' applications against our ethical statement and conduct due diligence in line with our anti-money laundering policy.
    • We will end relationships with customers if there are indicators or concerns about modern slavery or trafficking and report it to the authorities (National Crime Agency following a Suspicious Activity Report).
    • We have a financial crime team made up of subject matter experts, which will investigate any suspicious activity or risk in this field.
    • We train our staff extensively. All new hires undertake mandatory training on 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 on identifying and supporting vulnerable customers and referring them to third party experts who can assist them.
  • Our marketplace partners. We expect our partners to meet Starling’s standards. We request a copy of the modern slavery statement for our largest Marketplace partners, both at onboarding and as part of annual due diligence review.

4. Our suppliers

Starling utilises services from third-parties predominantly located in the UK, US 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 the Supplier & Outsourcing Policy and Third Party Management Procedure, ensuring Vendors meet the Bank’s expectations on an ongoing basis.

We will work with the government, regulators and law enforcement to help identify and tackle modern slavery and human trafficking.

5. Looking ahead

As this is our first statement, there is more that we can do. In the next few months, we will develop a more comprehensive modern slavery policy, increase our training, and strengthen our processes where necessary.

6. Approval for this statement

This statement is made in accordance to the UK’s Modern Slavery Act 2015 and covers the financial period 2019/21 (1 Dec 2019 to 31 March 2021).

Anne Boden

Chief Executive Officer

29 September 2021

Approved by the Board of Starling Bank Limited on 29 September 2021.

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