Modern Slavery Statement

Modern Slavery and Human Trafficking Statement 2019

BMCE Bank International plc ("BBI")

This statement sets out the steps that BMCE Bank International plc ("BBI") is undertaking to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

BMCE Bank International plc ("BBI") has a zero-tolerance approach to any form of modern slavery. We are committed to acting in an ethical manner, 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.

Our customers and counterparties

How we do business is as important as what we do. We want to build trust with our stakeholders at BMCE Bank International plc ("BBI"). Part of that trust stems from our duty of confidentiality to our clients and customers, subject only to regulatory or legal obligations of disclosure.

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 have a responsibility to deter, detect and prevent illicit use of the financial system by criminals. We must be alert to the presence and activities of those who would otherwise abuse the banking facilities that we offer.

The commitments and policies in this statement apply to all who work for BMCE Bank International plc ("BBI"). We must seek, within our business dealings, to raise awareness of human rights and act as an example of good practice through our own business conduct.

Within BMCE Bank International plc ("BBI")

BMCE Bank International plc ("BBI") applies human rights considerations directly as they affect all employees; treating all employees with dignity and respect in an environment that is free from discrimination and harassment.

BMCE Bank International plc ("BBI") staff are made aware of their rights through a variety of channels, including written contracts and staff handbooks. Staff receive training on a variety of human rights related issues, including but not limited to diversity, money laundering, supplier management, terrorism financing and bribery and corruption.


Our Supply Chains / Outsourcing

The biggest risk of directly encountering modern slavery for BMCE Bank International plc ("BBI") lies where the Bank does not have direct management control. In particular this may include suppliers who provide support staff in, for example, catering, cleaning or security posts.

BMCEBankInternationalplc("BBI")hasaCodeofConductforSuppliers. Asarticulatedin this Code, BMCE Bank International plc ("BBI") 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 labour and child labour and 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, BMCE Bank International plc ("BBI") will include in contracts with suppliers an obligation to comply with the Code of Conduct for Suppliers.

BMCE Bank International plc ("BBI") recognises that its experience in this sphere is recent and still being acquired. It will be necessary to develop management information that will allow BMCE Bank International plc ("BBI") to confirm the effectiveness of its policies and procedures.

Protecting the financial system

BMCE Bank International plc ("BBI") is committed to maintaining effective 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. As well as seeking to identity modern slavery and human trafficking in our own operations and supply chains, banks have a responsibility to deter, detect and prevent illicit use of the financial system by criminals who may be seeking to conceal themselves in many guises.