Modern slavery act statement

In line with our purpose to use our financial expertise to do good for individuals, families, businesses and societies, our philosophy is to do business ethically and responsibly, with a focus on delivering positive societal and environmental impact.

We believe that human rights are integral to our business, and as such, we seek to do business with those who share our values. Financial institutions play a key role in addressing the scourge of modern slavery – firstly through our ability to identify, prevent and report on money laundering and suspicious transactions which may be linked to forms of modern slavery, but also because we recognise that a lack of access to legitimate financial services is a key driver of modern slavery.

At Nedbank, we have a robust stance against slavery and human trafficking and have for a long time been committed to ensuring financial inclusion in contributing toward socio-economic development, and at the same time, to mitigate against illicit activities such as money laundering and modern slavery.

We are committed to implementing effective systems and controls to ensure that we are able to detect, prevent, or mitigate against the occurrence of modern slavery in our business operations and in our supply chain to the greatest extent possible. Where modern slavery does occur, we will participate in legitimate processes relating to the provision of appropriate redress.

We are making this statement in in line with section 54(1) of the United Kingdom Modern Slavery Act 2015 (“Act”) for the financial year ending 31 December 2024. This statement provides an overview of our business, and the steps taken by Nedbank Private Wealth Limited to ensure that modern slavery and human trafficking is not taking place in our supply chains and business operations.

Who are we?

Nedbank Group traces its history back to the early 19th century with the establishment of the Cape of Good Hope Bank in 1831 and following successive branding and structural changes, Nedbank Group was formed in 2003. Nedbank Group has been listed on Johannesburg Stock Exchange since 1969.

Nedbank Private Wealth Limited is a separately capitalised company that is a private wealth bank operating across various jurisdictions. The office in the Isle of Man was opened in 1987 followed by the Jersey Branch in 1994, the London Branch in 2008 and the Dubai Representative Office in 2011.

We are a subsidiary of Nedbank Group.

As a financial institution, we offer a variety of products and services to our clients, including the provision of professional, personal wealth and asset management services to individuals and families.

Our approach to the governance of modern slavery

Nedbank has been long established, and we intend to continue supporting the generations to come. Our values are key to achieving our long-term goals with the collaboration of our employees. Ultimately, it is simply good business sense for us, and we recognise that our industry has a key role to play in promoting long term economic sustainability that should give way to a fairer society with opportunities of growth and development for every person.

We have adopted a holistic and coordinated approach to managing human rights in business by embedding an understanding of human rights risks and corresponding responsibilities across our business strategies and activities.

We consider other crimes such as bribery and corruption within our holistic approach, as we believe that these crimes are enablers of human right abuses, forced labour, modern slavery, trafficking of humans and other exploitation of humans and children.

Policies in relation to slavery and human trafficking

Our values are key to achieving our long-term goals with the collaboration of our employees.

We have a zero-tolerance policy towards modern slavery and human trafficking. Our policies are designed to ensure that all employees, clients and suppliers adhere to the highest ethical standards.

These policies are communicated to all relevant stakeholders and are included in our employee and supplier contracts.

We are committed to implementing effective systems and controls to ensure that we are able to detect, prevent, or mitigate against the occurrence of modern slavery in our business operations and in our supply chain to the greatest extent possible. Where modern slavery does occur, we will participate in legitimate processes relating to the provision of appropriate redress.

Risk assessment and management

Recruitment

Our recruitment process consists of pre-employment screening which may vary according to local legislation and aims to ensure that the person has the right to work thus managing any risks related to labour rights violations according to relevant local legislation.

Our recruitment process is also influenced by wanting to support our community and contribute towards their growth and development. For this purpose, we have adopted Diversity, Equality and Inclusion (DEI) criteria within our recruitment and Talent program. While this initiative may not be immediately synonymous with human rights abuse and modern-day slavery or trafficking of humans. We believe that we are addressing one of the root causes that can make people vulnerable to exploitation due to their financial position.

Organisational structure and supply chains

As a Bank, we offer financial products and related services, therefore our suppliers reflect the operational requirements and safeguards necessary to deliver what we promised to our clients. Although it is not possible to prevent and mitigate against all potential adverse human rights impacts across our entire supply chain, we endeavour to implement reasonable risk management processes as far as we are able to do so.

Supplier due diligence is conducted for all suppliers to identify any actual or alleged illicit or unethical activities, including their involvement in human rights violations. The level of due diligence conducted is similarly dependent on the supplier’s risk level. High-risk and high-contract-value suppliers undergo frequent due diligence assessments.

This includes reviewing their policies and requiring them to sign our terms of business. We also monitor existing suppliers regularly to ensure ongoing compliance.

We have implemented a risk assessment process to identify and manage the risks of modern slavery in our operational activities and supply chains. This process involves mapping the inherent risks posed to our institution and our supply chains, identifying high-risk areas, and developing action plans to mitigate these risks.

Due diligence processes

Our client due diligence process provides us with a holistic overview of the risks associated with the client base on risk factors such as the product or service, the geographical operational footprint, supply and delivery chain, business sector and third party’s involvement to name a few. The risks considered cover all financial crime which includes modern-slavery and trafficking of humans. It also considers other associated risks and perceived enablers to modern-slavery, forced labour and trafficking of humans such as Human Rights sanctions and corruption.

Training and awareness

All employees are required to read and acknowledge our key policies on an annual basis and receive mandatory training at onboarding and annually thereafter in order to detect and report incidents of financial crime to which modern slavery and human trafficking are defined as predicate money laundering offences.

Our financial crime and client due diligence procedures require our employees to be fully aware of what is required of them, and receive specific training in relation to this risk.

However, we can always do more to ensure that general awareness of these crimes can be improved.

Reporting

We encourage our internal and external stakeholders to report confidentially any actual or suspected illicit activities, unethical behaviour, or adverse human rights impacts or concerns through our various reporting mechanisms.

We are committed to continuous improvement in our efforts to combat modern slavery. We regularly review and update our policies, conduct audits, and engage with stakeholders to ensure that our actions are effective. We also encourage employees and suppliers to report any concerns or incidents of modern slavery through our escalation channels and our whistle-blowing procedures.

We also encourage members of the public and third-party organisations to report cases where NPWL, its agents or a supplier are in breach of our modern slavery statement.

Additional measures taken during 2024

We know that our actions and decisions have the potential to affect (both positively and negatively) virtually the entire spectrum of human rights – ranging from employment practices and our lending or investment activities to the supply chain. In recognising this, are looking to enhance our policies, frameworks and statements which aim to give effect to our obligations to respect and uphold human rights, and to drive positive impact in society.

NPWL take ongoing enhancements in our frameworks very seriously with a robust governance framework.

This includes reviewing all third-party relationships regularly with the enhanced focus on risk posed by the industry to modern day slavery.

We will continue to monitor the threats of modern slavery to ensure we update our processes and procedures to meet international best practice.

At NPWL, we are dedicated to ensuring that our business and supply chains are free from modern slavery and human trafficking. We will continue to take proactive steps to identify and mitigate risks, and we encourage all stakeholders to join us in this commitment.