Julian Hodge Bank Limited (Hodge)is making this statement under the provisions of Section 54, part 6 of the Modern Slavery Act 2015. This statement sets out the steps taken by Hodge to ensure that neither slavery nor human trafficking (together, ‘Modern Slavery’) occur within its own operations or supply chains.
Modern Slavery is defined by the Home Office as:
“The legal exploitation of people for personal or commercial gain. Victims are trapped in servitude, which they are deceived or coerced into, and feel they cannot leave. It includes human trafficking. Common forms of exploitation include domestic servitude, sexual exploitation, forced marriage, forced criminality and forced labour”.
Hodge has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings with relationships.
Hodge is an independent, privately-owned financial services group operating from its head office in Cardiff . We employ more than 300 people and for more than 50 years, we’ve shared the same simple mission: to make a positive difference for our customers and communities. This ethos is in our DNA as we are 79% owned by a charity, the Hodge Foundation.
Hodge has already seen a large amount of growth both in terms of financial performance and colleagues. Our strategic vision is underpinned by our people and our investment in our colleagues. Our culture is what makes us special and ultimately what delivers our purpose to make a positive difference for our customers and communities.
Our aim is to open financial possibilities where options seem limited. Helping a family get a mortgage, saving for that dream or investing in, or developing, property. All of our customers get much more than just products -we give them simple solutions and support when they need it most.
Our values and supporting policies reflect our commitment to act ethically and with integrity.
We have a whistleblowing policy which enables colleagues to report any concerns related to our business dealings. The policy is designed to ensure matters raised under this policy are investigated thoroughly, promptly and confidentially and without fear of victimisation.
We have communicated this statement to all our colleagues to ensure there is a high level of understanding of the risks of modern slavery to our businesses and to our supply chain.
National Living Wage
Hodge is committed to being a fair and reasonable employer and ensures that salaries remain competitive within its market through a variety of methods, including role evaluations and external benchmarking. We ensure that all colleagues are paid at least the national living wage, regardless of age.
Supply chains – outsourcing and third parties
Hodge considers the financial services industry in the United Kingdom to be a low risk industry in relation to modern slavery.
Our third-party relationships are mostly with firms in the United Kingdom, that are considered to be low risk based on jurisdiction and very limited number of firms in US in low-risk sectors (such as Technology/software licenses).
As such, Hodge takes a risk-based approach to the engagement of third-party suppliers and will carry out due diligence checks on all suppliers where it believes there is a risk of exposure to modern slavery within their operations.
Governance and risk management
A governance and risk management framework are in place to support adherence to policies/procedures and to identify risks faced by Hodge.
This is based on a “three lines of defence” model which includes the front line being responsible for risk identification, assessment and mitigation; the second line providing oversight and third line providing independent assurance.
This Statement is signed on behalf of the board by David Landen, Chief Executive Officer.