Slavery & Human Trafficking Statement 2017

Introduction & Organisational Structure
Reclaim Fund Ltd (RFL), a wholly owned subsidiary of Co-operative Banking Group Ltd, was established on 28 March 2011 following the introduction of the Dormant Bank and Building Society Accounts Act 2008. It is authorised and regulated by the Financial Conduct Authority, operates independently with an appointed Board and Executive, and is non-profit-making. (company no 07344884).

The principal activity of RFL is that of the management of dormant account monies which it has received since March 2011. The Dormant Bank and Building Society Accounts Act 2008 enables banks and building societies that choose to participate in the Dormant Accounts Scheme, to transfer money from their dormant accounts to RFL for distribution to Big Lottery Fund and then onwards to good causes across the UK. It also ensures that the right of account holders to reclaim their money is protected in perpetuity by transferring the individual’s claim against their bank or building society to RFL.

Whilst pursuing our Purpose and Vision, we are committed to combating slavery and human trafficking and will take all reasonable measures to ensure a strong ethical framework is in place.

Our Policies
Risks are regularly reviewed by our Executive Risk Committee, Audit and Risk Committee and Board. Our policies are embedded into our Governance and are reviewed regularly. The following policies reflect RFL’s approach to the Modern Slavery Act:
Modern Slavery
HR Processes and Policies

The Slavery & Human Trafficking Statement which forms part of our Modern Slavery policy, will be reviewed and approved annually by the Board.

Due Diligence & Risks
RFL’s supplier management approach involves categorisation of our key and other suppliers; the frequency and depth of monitoring and review of each supplier is dependent upon this categorisation and is explained in our Supplier Relationship Management Plan (SRMP).

RFL has a relatively small number of suppliers and service providers and as a result has adopted a 2-tier approach, tier 1 being those suppliers who publish a modern slavery statement and tier 2 being those who do not.

Tier 1; We will review annually the Modern Slavery statements already published by some of our suppliers to establish whether their stated approach meets the terms of the Modern Slavery Act. Where statements are insufficient further action will be taken as necessary.

Tier 2; RFL will communicate with these suppliers, explaining that we comply with the Modern Slavery Act and state that we expect them to comply also. Any instances of non-compliance will be assessed and remedial action will be taken, initially engaging with the supplier to resolve any issues within an agreed timescale. If this is not resolved to RFL’s satisfaction, then the service with the supplier will be terminated and a different supplier sourced.

Modern Slavery mitigation will be written into the Tendering and Contract process undertaken for any new suppliers.

RFL takes its responsibilities as an employer very seriously as demonstrated by its Living Wage and Investors in People accreditations. Our HR policies and procedures underpin this approach and we work closely with all related parties to ensure we continue to meet the objectives of the Modern Slavery Act.

We will measure and record the results of our Modern Slavery Act related risk assessments on an annual basis; this will include KPIs for Key Suppliers.

We roll out regular Mandatory Training to all our employees including Whistleblowing and Equality & Diversity. This training has now been extended to include the Modern Slavery Act with additional specialist training provided to the relevant members of staff. RFL will continue to monitor training needs in relation to the ongoing development of our Modern Slavery Policy and Statement and address accordingly.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and was approved by the RFL Board on 26 May 2017.


Please click here to download a PDF of our statement.