Lloyds Banking Group is a leading UK-based financial services group encompassing well-known brands including Lloyds Bank, Halifax, Bank of Scotland and Scottish Widows.
With the introduction of the UK’s Modern Slavery Act in 2015, the Group wanted expert advice on how to respond credibly and strategically to the requirements of the Act. They also commissioned Sancroft to support with the production and drafting of the modern slavery statement and a human rights policy statement over a period of five years, as well as provide ad hoc advice on modern slavery and human rights.
Sancroft began with an assessment and gap analysis of the company’s existing policies and processes against the Act’s reporting criteria. This was based on engagement with multiple internal and external stakeholders to ensure that multiple perspectives were considered and incorporated. Using content gathered through document review and stakeholder engagement, we drafted an industry-aligned statement and provided recommendations for areas of improvement to help the Group strengthen its approach to tackling modern slavery. Recommendations were based on international human rights standards and learnings from the wider industry.
In parallel, Sancroft supported the bank to develop its first Human Rights Policy Statement which sets out the Group’s approach to human rights, and the policies and processes in place to manage risks.
Lastly, we delivered training for different functions to educate them on modern slavery risks and the importance of addressing them.
As a result of this work, the business understood the requirements of the Act, its relevance to their business, and what work was already underway across multiple business units.
Our work provided Lloyds Banking Group with a robust industry-aligned Modern Slavery Statement and Human Rights Policy. The client was also armed with insights on how to strengthen their approach to tackling modern slavery and communicating their progress over time.
Sancroft continues to support the Group to strengthen their human rights strategy.