Introduction
Bank of London and The Middle East plc (‘BLME’) is a Sharia’a compliant bank authorised by the Prudential Regulation Authority (‘PRA’) and regulated by the Financial Conduct Authority (’FCA’) and the PRA. BLME values traditional finance principles, and strives to be straightforward, competitive, and prudent. We are committed to acting ethically in all our business relationships, as well as complying at all times with laws and regulations applicable to us.
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 (‘the Act’) and constitutes our slavery and human trafficking statement for the financial year ended 31 December 2022.
Organisational structure
BLME was incorporated in England & Wales in 2006 and received a banking licence from the UK Financial Services Authority in 2007. BLME’s immediate parent company is BLME Holdings Limited a company incorporated in England & Wales in 2013; and its ultimate parent company is Boubyan Bank K.S.C.P. a public shareholding company incorporated in Kuwait and listed on the Kuwait Stock Exchange. BLME employs approximately 140 permanent staff in its London offices as well as thirteen staff in its Dubai branch in the UAE and fourteen staff in its new subsidiary in the Kingdom of Saudi Arabia.
Supply chains and due diligence procedures
BLME’s supply chain includes but is not limited to third party suppliers (‘Suppliers’) of the following goods and services: consultancy services; IT and telecommunications; legal services; audit services; valuations; marketing; consumables; office services; recruitment and travel. As a financial services provider, BLME does not directly have a high-risk exposure of modern slavery or human trafficking, but we are committed to ensuring through our due diligence process and supplier attestation that our supply chain complies with all relevant legislation, regulation, and directives in their respective countries. It is our intention that all current and future relationships with our Suppliers will be managed with this commitment in mind, and we will not knowingly do business with any third party guilty of non-compliance.
Accordingly, appropriate due diligence procedures have been established to assess any risk of slavery or human trafficking in our supply chain. To this end, it is our policy to seek confirmation from all our new Suppliers identified as operating in “at risk” areas that they comply with their obligations under the Act; and, if they are not covered by the Act, they will be asked to provide evidence of the work to eliminate human trafficking and slavery from their own business and supply chain.
Training and policies
Internal training is central to ensuring that BLME staff understand the bank’s obligations under the Act, and that potential risks of slavery or human trafficking issues are identified. Accordingly, appropriate training sessions have been provided to staff, and BLME’s policy for onboarding suppliers informs staff of the practical steps to be taken to address the Act’s requirements.
Approval procedure
This statement, which will be reviewed annually, has been approved by the Board of Directors of BLME.
Andrew Ball, Chief Executive Officer, BLME
15 June 2023
