MODERN SLAVERY STATEMENT
This statement is made on behalf of Habib Bank Zurich Plc (company number: 08864609) (the Bank) pursuant to section 54(1) of the Modern Slavery Act 2015 (the Act) and constitutes our slavery and human trafficking statement for the financial year ended 31 December 2024. This statement sets out the steps that the Bank continues to take to prevent modern slavery and human trafficking in our business and supply chains. The Bank strictly opposes modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships both with our staff and our suppliers.
Our Structure
Habib Bank AG Zurich, the Bank’s parent company, was established in Switzerland in 1967.
Habib Bank AG Zurich has a head office in Zurich, and operates with branches in Zurich, Kenya and the United Arab Emirates. It has subsidiaries in Canada, Hong Kong, Pakistan, South Africa, and the United Kingdom, and representative offices in Bangladesh, China, Hong Kong, Pakistan, and Turkey.
The Bank commenced operations in the United Kingdom in 1974 as a branch of Habib Bank AG Zurich. In 2016, Habib Bank Zurich, a wholly-owned subsidiary of Habib Bank AG Zurich Switzerland, took over the operations of the UK branch.
Habib Bank Zurich is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority, with registration number 627671 in the Financial Services Register.
Business & Supply Chains
The Bank is governed by the Board of Directors, which is supported by a number of committees to ensure compliance with all applicable regulatory requirements. The Board is responsible for the overall strategic direction of the Bank.
The Bank’s key business lines are short and long term finance, loans and overdrafts, trade finance facilities, savings, fixed term deposit and current accounts and Islamic banking products. Our products and services are largely provided direct through our network of eight UK branches, as well as through our website for our fixed bond offerings. At the end of 2024, the Bank had around 158 employees.
As a financial services provider, our supply chain predominantly consists of UK-based suppliers of technology and professional services, as well as utility and office supply vendors (such as cleaning, repair and maintenance, stationery suppliers, security services, etc.).
The Bank outsources a number of services, including payment processing, trade finance and our customer call centre, to other HBZ Services within the Group.
Controls
The Bank is fully committed to maintaining effective systems and controls to ensure that the abhorrent practices of modern slavery and human trafficking do not take place in our business or supply chains.
We have a robust approach to ethics and compliance, and the Bank’s values are based on its commitment to honesty and integrity in everything we do.
The Bank’s governance framework and related corporate policies such as Code of Conduct, Whistleblowing, and dedicated training empower our employees to report and escalate any concerns of unethical conduct, whether relating to concern about modern slavery and human trafficking or other matters.
The Board is ultimately responsible for our compliance with the Act. Two departments will be responsible for the day-to-day management. The Chief Financial Officer, responsible for external vendors, and the Head of Human Resources, responsible for employment and remuneration matters to ensure fair pay and ethical workplace practices. Oversight is provided by the Compliance Team.
All employees receive an Employee Handbook at the time of onboarding, which is available on the intranet.
Employment Practices
The Bank aims to be a responsible employer that provides staff with good working conditions and opportunities for personal growth. Through various policies and initiatives, we aim to ensure that every colleague feels safe in their workplace, has a true sense of belonging, is respected for who they are and experiences a healthy working environment.
The Bank complies with all applicable employment legislation and maintains policies and practices which include background checking on all new employees and the use of reputable and trusted agencies for recruitment and pre-employment screening of permanent, temporary and fixed-term workers.
As part of our due diligence, we regularly assess recruitment agencies for compliance with employment laws, data protection, and screening standards. Selection is based on clear criteria, including reputation, client feedback, existing relationships, and ethical practices. Service agreements outline our compliance expectations, and agency performance is reviewed periodically to ensure ongoing alignment with our standards and legal requirements.
All terms and conditions are shared prior to employment and policies are made available to all new staff on joining and then are available on our intranet. This includes the Bank’s complaint and grievance mechanisms and whistleblowing policies.
All Bank employees are expected to behave in accordance with our Code of Conduct which is supported by training. In particular, the expectation that employees act in alignment with our core values is made clear through a transparent induction process and ongoing training.
The Bank’s policies and procedures are reviewed at least every three years, unless changes to legal and regulatory requirements necessitate more frequent updates.
Anti-Bribery & Corruption Policy
The Bank’s Anti-Bribery and Corruption policy outlines the responsibilities of our staff in observing and upholding the Bank’s position on bribery and corruption.
Anti-Money Laundering Processes & Controls
As a financial institution, the Bank recognises the inherent risk of providing services like cash management, Lending, Trade, Treasury, FX & FI which may have the potential to be associated with Modern Slavery. . To address this risk, the Bank has established stringent anti-money laundering processes and controls, supported by comprehensive policies on sanctions, fraud, and financial crime. These measures include robust transaction monitoring systems and other oversight mechanisms aimed at detecting and preventing all forms of money laundering and related illicit activities.
Vulnerable Customer Policy
The Bank has established a Vulnerable Customer Policy and ensures the identification of the clients and provides training to employees to support them in understanding vulnerability and addressing it with empathy, ensuring that customers in vulnerable circumstances receive the support they need.
Due Diligence
As part of our onboarding process, both clients and suppliers undergo due diligence and screening proportionate to their level of risk, to ensure that the Bank operates within the applicable regulatory guidelines, including those related to anti-money laundering and counter-terrorist financing.
The Bank carefully selects its suppliers to assess whether they are ethical, suitable and trustworthy.
Periodic reviews are carried out on our contractual arrangements with suppliers to maximise consistency and transparency in those relationships.
Risk Assessment & Measuring Effectiveness
Given the nature of the Bank’s business, we have assessed the risk of modern slavery within our business and supply chains to be low. However, we are not complacent and recognise that this is an on-going risk. We are committed to continually developing our approach, educating our employees, and assessing and managing risks on a continuing basis.
Further Steps & Targets for the Year Ahead
The Bank will continue to keep under review our internal processes to identify what further measures can be taken to ensure that our obligations under the Act are met.
Some specific measures we will progress during the 1st and 2nd quarter of 2026 include:
- As part of the Bank’s commitment to ensuring that employees are aware of and comply with relevant legislation, a dedicated online Modern Slavery training module and assessment will be introduced in Q, 2026. All employees will be required to complete annual refresher training, and the module will also form part of the Bank’s induction programme
- The Bank will continue with periodic reviews of our contractual arrangements with suppliers to maximise consistency and transparency in those relationships
- Considering how we can strengthen our contractual arrangements to ensure alignment to our values
Conclusion
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Habib Bank Zurich’s slavery and human trafficking statement for the financial year ended 31 December 2024.
This statement was approved by the Board on 27 November 2025 and signed on behalf of the Board by the Chief Executive officer.
Satyajeet Roy
Chief Executive Officer