Bank of Africa United Kingdom is an international bank with a passion for Africa. We were set up with the belief that Africa is open for a new kind of business that is modern and African-driven. Our passion for Africa drives our work. As a result of many years of working on the continent, we have detailed experience of business there. We understand the modern cultural and commercial realities of investing in Africa and how best to structure deals and distribute the continent’s opportunities to the wider world.

We believe that successful investment is underscored by ethical principles. All of our work is executed with integrity and transparency to ensure both the highest quality of service and commercial success. We ensure a strong level of corporate governance to provide robust checks on internal systems.

Our staff are key to the success of our business. Their expertise, teamwork and professionalism are the cornerstones of Bank of Africa United Kingdom's ability to deliver to the highest international standards. To ensure they can flourish, we have an inclusive approach, respecting all our team members and contacts. This teamwork extends to each of our international offices. We encourage open cooperation between regional offices and our headquarters, creating an environment in which ideas and experience are respected in order to make the best of our teams’ expertise.

We aim to provide efficient and high quality services that respond to our clients’ needs. This requires us to have a close and reliable relationship with our clients.

We have confidence in Africa’s future and a firm belief that the continent provides a wealth of opportunities with decreasing and manageable risks. Opportunities on the continent are increasing due to a combination of sustained economic growth, strengthened political and corporate governance, and macroeconomic reform.

Our corporate social responsibility strategy is based on core values of professionalism, ethical business practice, and mutual cultural adaptation.

We firmly believe that the best way to support development in Africa is for us to bring business to the continent thus directly contributing to people’s livelihoods through job creation and improved infrastructure. We execute our roles to the highest commercial and ethical standards.

By recognising and actualising the opportunities that exist in Africa, we can contribute to the sustained development of the continent and its communities.

This is the Anti-Bribery Policy Statement of Bank of Africa United Kingdom:

Anti Bribery Policy Statement:

Bank of Africa United Kingdom expects its employees to demonstrate honesty, integrity and fairness in all aspects of their business dealings and exercise appropriate standards of professionalism and ethical conduct in all their activities. Bank of Africa United Kingdom also expects the same approach to doing business from its business partners, contractors and suppliers.

Pursuant to this Bank of Africa United Kingdom will not tolerate bribery or corruption in any form and has a “zero tolerance” approach to any breach of this policy.

Application:

This means that Bank of Africa United Kingdom and its employees will never seek, accept or give a bribe, facilitation payment, kickback or other improper payment. We must also always ensure that we operate with appropriate transparency in all our business dealings.

Bank of Africa United Kingdom Policy:

• We will carry on our business fairly, honestly and openly;
• We will not make bribes so as to gain a business advantage nor will we condone the offering of bribes on our behalf;
• We will not accept bribes to influence business nor will we agree to bribes being accepted on our behalf;
• We will avoid doing business with others who do not accept our values and who may harm our reputation;
• We will maintain processes, procedures and records that limit the risk of direct or indirect bribery;
• As far as possible we will ensure that all our business partners are aware of our bribery policy;
• We promote employee awareness of, and compliance with, company policies and disciplinary actions against bribery and corruption through appropriate dissemination of our own procedures and training programs on an ongoing basis;
• We do not make illegal or inappropriate contributions to candidates for public office or to political parties or organisations;
• We will review this policy regularly and update it when necessary.

Bank of Africa United Kingdom Plc (the Bank) has established and continues to maintain its Financial Crime Prevention Policy which is designed to ensure that all its business lines are in compliance with all applicable laws, rules and regulations related to anti-money laundering (“AML”) anti-terrorist financing initiatives (“CTF”) and all other forms of financial or economic crime.

The Bank recognizes the fact that money laundering and terrorist financing is a major threat to the international financial services community. The United Kingdom has passed legislation designed to prevent money laundering and terrorist financing. This legislation, together with regulations, rules and industry guidance, forms the cornerstone of AML/CTF obligations for UK firms, including offences and penalties for failing to comply.

The following are the main elements of the policy: Internal Controls and Communication of Policies:

The Bank has instituted internal systems and controls which comply fully with all applicable anti-money laundering laws and regulations. Senior management will undertake money laundering risk assessment of the Bank’s services and customer base and apply the appropriate policies and procedures to manage the risk.

Money Laundering Reporting Officer:

The appointment of a Money Laundering Reporting Officer, of sufficient seniority who has responsibility for oversight of the Bank’s compliance with the relevant legislation, rules and regulations industry guidance. The MLRO has the oversight of all aspects of the Bank’s AML/CFT activities, policies and procedures and is the focal point for all activity within the Bank relating to anti-money laundering.

Risk Based Approach:

The Money Laundering Regulations 2007 to 2017 allow the Bank to adopt a carefully calibrated risk-based approach to money laundering/ terrorist financing by assessing where the risks of money laundering may arise in the Bank and allowing the Bank's senior management to decide how they will address and manage those risks. The Bank carries out such an exercise or a review annually to establish and maintain an updated Risk Based Approach towards assessing and managing the money laundering and terrorist financing risks to the Bank.

Customer Due diligence:

Before establishing business relationship with any prospective customer, appropriate customer due diligence (CDD) is required to be undertaken and recorded. The CDD/KYC process comprises: 1) the identification and verification of identity of the customer (and, where different, beneficial owner) and any other relevant parties; 2) additional and appropriate Know Your Customer (KYC) information, applying a risk based approach; 3) obtain basic background information about the customer identified as PEP i.e. customer’s business and source of income, extensive research will also be carried out accessing available press pronouncements to gauge the credentials of the PEPs; 4) enhanced due diligence will be carried out for higher-risk customers, knowledge of the customer will be updated on a regular basis in our internal system which will enable our AML software tool automatically make necessary changes for performing accurate customer activity/transaction monitoring exercise against expectations; 5) identification of ultimate beneficial owner of all companies with which the bank conducts business and the beneficial ownership of all funds or other assets that are handled by the bank;

Financial Sanctions and Ongoing Screening:

The Bank endeavours to take reasonable steps to ensure that it is not breaching EU, UK and UN financial sanctions. We recognize the fact that financial sanctions regimes change in the light of national and international political developments and names are therefore added (and removed from) the HM Treasury sanctions list maintained in their website, hence we have put in place systems and controls in respect of ongoing screening of our customer base against sanctions list. We ensure that our client base is screened automatically following direct notification of such changes from HM Treasury. In addition to that Bank also implemented automated periodic checking against up-to-date sanctions list.

Identification of Suspicious Transactions/ Activity:

It is a requirement that our Systems and Controls ensure that appropriate scrutiny and monitoring of transactions, account activity of customers is undertaken in order to identify unusual and potentially suspicious activity.

Reporting of Suspicious Transaction:

We have procedures in place whereby every transactions and activities which are believed to be suspicious are reported to the Money Laundering Reporting Officer where the suspicion will be validated, and decision will be made as to whether a report should be made to NCA (National Crime Agency).

Record Keeping:

Records are required to be maintained and ongoing KYC/CDD procedures have been followed. Records are required to be maintained for 5 years after the relationship has ended.

Politically Exposed Person:

The Bank have systems and controls in place to identify PEPs as part of client take on and thereafter on an ongoing basis (e.g. account review, information received during the continuing relationship). For such accounts it is a requirement to identify the source of wealth and source of funds. All relationships involving PEPs are subject to approval by the senior management. The accounts concerned will be kept under close review by AML/KYC Analysis. Any suspicion that accounts are being used to launder the proceeds of crime or to assist the financing of terrorism will be reported to the MLRO.

Counterparties:

The Bank maintains procedures in relation to the relationships with the counterparties including banks in line with the UK JMLSG (Joint Money Laundering Steering Group Guidance) Guidance for the Financial Sector. Where necessary, this comprises enhanced due diligence (EDD) by obtaining information on a counterparty or client's ownership and management, noting any PEP involvement in the operation of the counterparty or client, obtaining information to fully understand the nature of its business, verifying the standard of anti-money laundering and terrorist financing controls as well as measures designed to prevent relationships being maintained, directly or indirectly, with shell banks.

Awareness and Training:

Ongoing annual training provided to all existing staff members to ensure that they understand Bank’s approach to money laundering deterrence.

Disciplinary Procedures:

Failure to abide by the policies and procedures set by the Bank to prevent money laundering will be treated as a disciplinary issue. Any deliberate breach will be viewed a gross misconduct. This could lead to termination of employment and could also in criminal prosecution for the member of staff concerned.

This statement outlines the steps that Bank of Africa United Kingdom Plc (the "Bank") is undertaking to ensure that modern slavery or human trafficking is not occurring within our business or supply chain.

Bank of Africa United Kingdom Plc has a zero-tolerance approach to modern slavery. We are committed to acting ethically, with integrity and transparency in all business dealings.

We are committed to creating effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain and impose those same high standards on our contractors, suppliers, and other business partners.

Post - COVID-19 Pandemic

Bank of Africa United Kingdom Plc has continued to monitor the risk of modern slavery in its operations and supply chains. While travel and entertainment are considered high-risk sectors in our supply chain concerning modern slavery, activity in travel and entertainment has been minimal when Covid-related restrictions were in place. As day-to-day activity has returned to normal, this area remains below what was seen pre-Covid. Centralised processes are in place to ensure that any action in this area is monitored and that, where appropriate, any activity is booked using the approved providers.

Our customers and counterparties

How we do business is as important as what we do. We want to build trust with our Bank of Africa United Kingdom Plc stakeholders. Part of that trust stems from our duty of confidentiality to our clients, subject only to regulatory or legal disclosure obligations.

Slavery and human trafficking are crimes. The criminals responsible will seek to hide the proceeds of their crimes in the financial system to legitimise them. Effectively, money laundering and banks are responsible for deterring, detecting, and preventing criminals' illicit use of the financial system. We must be alert to the presence and activities of those who would otherwise abuse our banking facilities.

We recognise the need to manage social and environmental aspects in our business dealings. Accordingly, we apply human rights and modern slavery considerations in our due diligence processes relating to our lending and financing activities. We shall continue to enhance and strengthen these processes not only at the bank level but also at the group level.

The commitments in this statement apply to all who work for the Bank of Africa United Kingdom Plc, regardless of where they are located. In our business dealings, we strive to raise awareness of human rights and act as an example of good practice through our business conduct.

Within Bank of Africa United Kingdom Plc

Bank of Africa United Kingdom Plc applies human rights considerations directly as they affect all employees, treating them with dignity and respect in an environment free from discrimination and harassment.

We are committed to operating by the International Bill of Human Rights and consider the UN Guiding Principles on Business and Human Rights and other internationally accepted standards, including the International Labour Organization Declaration on Fundamental Principles and Rights at Work.

These commitments are reflected in our policies, which set the standard of expected business behaviour for all employees and include our staff handbook, which aims to foster a workplace environment that is fair, open, and respectful and one that promotes and protects the rights and dignity of all employees as well as our whistleblowing policy which encourages staff to report any concerns about illegal activity. In addition, we keep our policies under constant review and, where required, strengthen them to embed further our commitment to combatting modern slavery and other related issues.

Bank of Africa United Kingdom Plc staff know their rights through various channels, including written contracts, policies, and staff handbooks. In addition, staff receive training on various human rights-related issues, including but not limited to diversity, money laundering, supplier management, terrorism financing, bribery, and corruption.

Our Supply Chains / Outsourcing

The most considerable risk of directly encountering modern slavery for Bank of Africa United Kingdom Plc lies where the Bank does not have direct management control. In particular, this may include suppliers who provide support staff, for example, catering, cleaning or/ security posts.

Bank of Africa United Kingdom Plc has a Code of Conduct for Suppliers. As articulated in this Code, Bank of Africa United Kingdom Plc requires suppliers to respect the human rights of their employees and the communities in which they operate, as well as to comply with all relevant legislation, regulations and directives in the countries and communities in which they operate. Suppliers must prohibit the use of forced and child labour, respect labour rights, including non-discrimination and the right to freedom of association, and give workers, whether local or migrant, the right and the ability to leave employment when they choose to the extent possible under local law.

Whenever possible, Bank of Africa United Kingdom Plc will include an obligation to comply with the Code of Conduct for Suppliers in contracts with suppliers.

Protecting the financial system

Bank of Africa United Kingdom Plc is committed to maintaining adequate financial crime controls. As stated above, slavery and human trafficking are crimes, and those responsible will seek to hide the proceeds in the financial system to legitimise them – effectively, money laundering. Therefore, as well as seeking to identify modern slavery and human trafficking in our operations and supply chains, the Bank have a responsibility to deter, detect and prevent the illicit use of the financial system by criminals seeking to conceal themselves in many guises.

Bank of Africa United Kingdom Plc see the risk of directly employing victims of modern slavery as low. However, we are committed to ensuring our supply chain is free from these practices. Of our leading suppliers, most do business in the UK or Europe or offer low-risk products or services. Some suppliers are located in higher-risk countries or offer higher-risk services such as security, cleaning and catering. Bank of Africa United Kingdom Plc only use reputable recruitment agencies that provide the necessary assurances and checks on candidates. Bank of Africa United Kingdom Plc further undertakes reviews, including document checks, ensuring all candidates are 16 or above. We pay our staff appropriate market salaries, rewards, and other benefits, including health and welfare options.

Training, awareness, and development section on modern slavery is included in the Bank's financial crime training programme, which is mandatory for all staff. We have also provided additional guidance to staff directly involved in procurement to help them reduce the risks of modern slavery in our business and supply chain.

Governance

Our Modern Slavery and Human Trafficking Statement and Supplier Code of Conduct are updated and reported annually to the Board of Directors.

At Bank of Africa United Kingdom, we are committed to good corporate governance and recognise that it is fundamental to our success. Our corporate governance framework is supported by a comprehensive set of policies, procedures and systems to ensure effective oversight and strong accountability throughout our business.

Effective oversight and strong accountability

Three committees at the Board level :

• Risk Committee
• Audit Committee
• Remuneration and Governance Committee

coupled with seven committees at the Executive level:

• Management Committee
• Asset-Liability Committee
• Compliance Committee
• Credit Committee
• New Product Committee
• Provisions Committee
• Large Exposures Committee

and newly added committees:

• Operational Risk Committee
• Outsourcing Committee

that meet regularly to ensure effective oversight and strong accountability. Read more

The Board of directors of the Bank of Africa United Kingdom controls the operations of the bank in the UK and France. The Board meets quarterly, or as frequently as it is required to carry out its responsibilities.