Modern Slavery Act.

 

This statement comprises the Slavery and Human Trafficking statement of Onyx Ltd pursuant to section 54(1) of the Modern Slavery Act 2015 (‘MSA’) for the financial year ending 31 December 2020.


The Business

Onyx is a specialist UK savings and lending bank founded in 2011 to serve the needs of SMEs and individuals in the UK with a range of lending and savings products. We are a growing UK specialist bank that challenges the conventional approach of the mainstream banks, with our thoughtful and good-sense approach to the way we do business.

Given the nature of the Onyx’s operations, Onyx is at very low risk of exposure to Slavery and Human Trafficking issues. However, Onyx continues to take its responsibilities seriously and has sought ways to champion better work and working lives to raise awareness of the issues of Modern Slavery and Human Trafficking.


Supply Chains

Onyx does not act as a producer, manufacturer, or retailer of any physical goods and, as a financial services provider, it has a relatively straightforward supply chain compared to other sectors. It is not authorised to conduct any financial services outside of the UK; however, some supply chains can be complex in nature and therefore some outsourcing activity takes place outside of the UK.

We strive to achieve mutually advantageous supplier relationships, built on common values and expectations. It is our commitment to conduct business in a responsible and sustainable manner that underpins our engagement with third party suppliers, only working with those that resonate with our core values.

In order to take a proactive stance against Modern Slavery, Onyx asks that all of its staff and suppliers, such as cleaning contractors, recruitment consultants, stationery providers, design agencies and catering contractors, are expected to behave, and to be seen to behave, ethically at all times during the sourcing and supply of goods and services for the Onyx. Onyx regularly reviews the contractual terms in place with its preferred suppliers to ensure that they remain pertinent and proactive. These records are reported to and monitored on a regular basis by the Procurement team.

Additionally, all of the Procurement team and Relationship Owners are asked to always comply with the Chartered Institute of Purchasing & Supply’s Code of Professional Ethics. 

Onyx continues to comply with regulatory requirements on outsourcing, which require us to take all reasonable steps to avoid undue additional operational risk and to take all reasonable steps to ensure that a Service Provider has the ability, capacity and authorisation required by law to perform their outsourced functions, services or activities reliably and professionally.


Policies in relation to Slavery and Human Trafficking

Onyx recognises the role it shares with its suppliers in tackling the growing issues of Modern Slavery. The Onyx has zero tolerance to Slavery and Human Trafficking and places a duty on all staff to report any potential infringement arising either internally or externally. Detailed background checks are carried out by an independent firm prior to new employees commencing work with Onyx, which would capture any criminal records in respect of Slavery and Human Trafficking Offences.

Onyx also operates various practices, procedures and policies to ensure compliance with all human rights laws and UK employment laws. Key policies include the:

  • Code of Conduct and Ethics

  • Dignity at Work Policy

  • Disciplinary Policy and Procedure

  • Equal Opportunities Policy

  • Whistleblowing Policy


Actions Taken and Planned

Throughout the 2020 financial year, the Onyx has continued to build on the approach introduced over the past few years. We remain concerned and committed to tackling Modern Slavery where we can. Activities have included:


Due Diligence Processes

Although Slavery and Human Trafficking concerns are of a low risk to the business, Onyx has introduced an approach to ensure ongoing monitoring of suppliers. We assess and review Anti-slavery matters with existing suppliers at the time when each contract is reviewed and/or renewed, and always at inception with any new supplier. We  are also part of FSQS (Financial Services Qualification System), which is a community of financial institutions. It is operated by a third party, Hellios, which  is recognised for providing total supplier information and risk management solutions and we are confident that this partnership strengthens our ability to systematically monitor supplier activity, ensuring full compliance with our values and relevant legislation, including the MSA.

Onyx’s Procurement and Supplier Performance Management Policy governs the onboarding process and reinforces the importance of due diligence and supplier governance in relation to slavery and human trafficking issues, which as mentioned above requires our colleagues to act ethically and with integrity in all their business relationships.

By having the correct tools (such as the MSA Compliance database and FSQS) and regularly reviewing our policies, we can ensure that any occurrences are swiftly and severely addressed. Should any instances of Modern Slavery be identified, Onyx will take internal action and escalate to the relevant authorities, immediately suspending the employee or supplier.


Training

Identified business owners are asked to undertake training in respect of the MSA on an annual basis.


Measuring effectiveness

In 2020 so far, there have been no reported instances of Modern Slavery within Onyx or its Supplier Relationships. Onyx will continue to review and monitor its approach to Modern Slavery amongst our colleagues and suppliers on a regular basis.