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Responding department: Group Sustainability Management

Stock exchange Symbol: (SBK:SJ)

Does your company have a publicly available commitment to respect human rights?

Yes, Standard Bank Group Human Rights Policy Standard Bank and Liberty are committed to upholding the principles of the Constitution of the Republic of South Africa, the associated Bill of Rights and labour legislation in our South African operations. Outside South Africa, we operate to similarly high standards. Standard Bank’s values and the code of ethics apply across all bank operations and are an extension of this commitment, which we aim to embed in the behaviour of all our employees. Our groupwide human rights policy recognises the need for SBG to respect, protect and remedy human rights. Actual wording from Standard Bank Group Human Rights Policy Statement: The Standard Bank Group (SBG) is committed to contributing to the sustainable development of the markets in which it operates, consistent with the nature and size of its operations, through ethical and responsible financing and business practice. It recognises that part of its corporate responsibility is to protect and uphold human rights in its operational practice and financing activities in line with the UN’s Guiding Principles on Business and Human Rights. The UN Framework on Business and Human Rights addresses the primary duty of States to protect against human rights abuses including those committed by business enterprises and state owned enterprises; and, the responsibility of business to respect, protect and remedy human rights abuses with which they are involved. We endorse the foundational principles contained in Section II of that report. “ (11) Business enterprises should respect human rights. This means that they should avoid infringing on the human rights of others and should address adverse human rights impacts with which they are involved. (12) The responsibility of business enterprises to respect human rights refers to internationally recognized human rights – understood, at a minimum, as those expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work. (13) The responsibility to respect human rights requires that business enterprises:

(a) Avoid causing or contributing to adverse human rights impacts through their own activities, and address such impacts when they occur;

(b) Seek to prevent or mitigate adverse human rights impacts that are directly linked to their operations, products or services by their business relationships, even if they have not contributed to those impacts.”

The SBG will:

  • Treat all our stakeholders fairly and with dignity, irrespective of race, colour, gender and disability, language, religion, political affiliation, national or social origin, or other status.
  • Reflect the human rights of our employees in our employment policies and practices, including the right to freedom of association and collective bargaining.
  • Seek to prevent or mitigate adverse human rights impacts that are (a) directly linked to our operations, products or financial services and (b) which may result from our lending activities.
  • Maintain a whistle blowing capability as part of our Ethics and Fraud hotline to enable anyone who believes we have infringed their human rights to report the infringement.
  • Maintain a policy commitment to respect human rights that includes conducting human rights due-diligence processes to identify, prevent and mitigate human rights impacts, and
  • Remedy any human rights impact that we may cause or to which we contribute.

We will: Maintain employment policies and practices that uphold the fundamental labour rights of employees, including the right to safe and healthy work environments and the right to organise and bargain collectively.

We will not: Engage in child, forced or compulsory labour or finance activities which infringe on these rights. Standard Bank Group Code of Ethics This code is designed to empower employees and enable faster decision-making at all levels of our business according to defined ethical principles. It is aligned with other Standard Bank policies and procedures, and supports the relevant industry regulations and laws of the countries in which we operate. The code of ethics has been certified by the Ethics Institute of South Africa as conforming to the highest international best practice standards.

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Employee relations:

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How are human rights governed in your company?

Lead responsibility for human rights sits with the Group Ethics Officer. The Social and Ethics Board Committee has oversight of human rights issues. Human rights are considered in our financing and credit decisions including at precredit and credit committee level. Financing decisions from DFIs require commitment to uphold human rights.

How are human rights managed within your company?

Actual wording from Standard Bank Group Human Rights Policy:

2.1 Human rights due diligence process

This process includes:

(i) Identifying and assessing any actual or potential adverse human rights impacts associated with our new business ventures and our lending

(ii) Using our risk management processes to mitigate risks and conducting ongoing monitoring.

(iii) Regular reporting through existing risk frameworks.

2.2 Remediation Standard Bank will record any complaints of human rights abuse and will constitute and maintain a transparent and legitimate process for resolving such conflicts whether these are related to our actions, or lack of actions, taking into account the interests of those who believe their rights are being violated. This process will be overseen by the Chief Ethics Officer. Corrective action shall be implemented where non-compliance with this policy is identified, overseen by the Group’s Chief Ethics Officer.

What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?

We have a number of internal forums which enable engagement on human rights issues with our employees. The Group Gender Forum acts as a source of advice on gender issues, in particular to increase understanding regarding the current challenges in recruiting, developing and retaining women at specific levels across the organisation, utilising best practice to appeal to women employees and customers, and providing input into product and service research. The Forum monitors our performance in terms of meeting our gender employment equity objectives in South Africa and facilitates communication between decision-makers and employees. The forum provides input into our diversity and inclusion strategy and initiatives as they relate to gender and creates an environment where gender issues and concerns can be raised and discussed confidentially. We have established a Disability Forum to assist us in identifying and remedying physical, social and attitudinal barriers that employees with a disability might face. We have around 69 Diversity and Transformation Forums across Standard Bank as part of our Employment Equity commitment. We do not tolerate any form of discrimination in remuneration. We monitor income differentials within and across job bands and levels to ensure that our remuneration practices do not discriminate on the basis of race, gender or disability. In South Africa we submit an annual income differential report to the Department of Labour, as required by the Employment Equity Act. We recognise that effective external stakeholder engagement is an essential part of good corporate governance and sustainable business. It enables us to understand and effectively address the concerns of those communities on which our business has an impact. We are at all times guided by South African legislation and global best practice, which commits us to respecting human and worker rights, protecting and sustaining the environment and fighting corruption and assisting with the social and economic development of the areas in which we operate and treating our customers fairly. Our stakeholder engagement activities are monitored by a board social and ethics committee. Our relations with all our external stakeholders are transparent and where necessary, recorded in our annual sustainability report.

Priority human rights issues: What are some of the priority human rights issues for your company?

  • Health (including environmental health, workplace health & safety)
  • Workplace diversity / non-discrimination
  • Housing
  • Freedom of association and trade union rights
  • Freedom of expression and/or right to privacy / digital rights
  • Women
  • Children (including child labour)
  • Indigenous peoples

Actions on workplace diversity / non-discrimination

The Human Capital Executive Committee approved the Standard Bank Group Disability Policy (Employees) in 2014. The purpose of this policy is to provide guidance in managing disability in the workplace, and to enable Standard Bank to fulfil its responsibilities in respect of incorporating people with disabilities into mainstream employment. The policy seeks to achieve this by:

1.1 Eradicating discrimination in decision-making about employees with disabilities in respect of opportunities for appointment, promotion, training and development.

1.2 Ensuring that employees with disabilities are protected from harassment and unfair discrimination.

1.3 Laying down guidelines for voluntary declaration of disability and provision of reasonable accommodation

Actions on housing

Standard Bank South Africa is committed to finding sustainable solutions that increase access to affordable housing finance for customers. We finance quality affordable housing units priced up to R550 000, with the average bond worth about R350 000. The household income level for units we finance is generally between R5 500 and R18 000 a month. We hold a 35% share of the affordable housing market in South Africa, financing one in every three houses. Some 81% of this finance was disbursed to first-time home buyers. Low-income earners who belong to pension and provident funds can enter into finance agreements with Standard Bank’s Pension-backed Lending unit to buy, build or renovate a home. We worked with the South African government to agree and introduce a revised government subsidy scheme, the Finance-Linked Individual Subsidy Programme, which is expected to benefit households that earn between R3 501 and R15 000 a month, further increasing access to home ownership. The Programme provides a once-off down payment to qualifying households that have secured mortgage finance to buy a residential property for the first time. This down payment will reduce the initial mortgage loan amount to render the monthly loan repayment instalments affordable over the loan payment term. We have signed a finance contract with the European Investment Bank which sets aside up to €30 million (about R433 million) for the financing of affordable housing developments. Under the initiative the European Investment Bank will contribute up to half of a housing schemes’ cost. Not only will the agreement improve housing for South Africans but it is expected to create over 6 500 construction jobs and will stimulate economic development.

Actions on freedom of expression and privacy

As a financial services institution, the privacy and security of our customers’ information is crucial. Our Data Privacy Policy sets out how we manage Data Privacy by maintaining and continuously improving our Data Privacy culture, safeguarding and protecting Personal Information and processing Personal Information in a lawful and reasonable manner.

Actions on 'other' issues

Women/Children (including child labour)/ Indigenous peoples

Included as part of our environmental and social appraisal process for activities we finance are human rights issues, including discrimination, child labour, forced or compulsory labour and the rights of indigenous people.

Compliance with the International Finance Corporation (IFC) 

Performance Standards are included in project financing contracts, which includes labour and working conditions with reference to human rights. Where human rights have been identified as a high-risk issue, this is specifically included in the loan contract. We engage directly with a number of our key clients and consultants on environmental and social advisory matters. Engagement takes place on all high-risk transactions, all project finance deals and project-related corporate loans.

Children/Education

Our CSI spend is focussed on education. We support the South African National Education Collaboration Trust, a partnership between government, the private sector, labour and academia, which intervenes at district level to improve educational outcomes. We also fund specific programmes, such as providing tuition in mathematics and science to learners from schools in township communities, and a Teacher Development Programme, which offers practising teachers in rural areas an opportunity to attend a series of up-skilling workshops.

How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?

Our human rights commitments are communicated on our sustainability website and in our assured Sustainability Report and our Annual Integrated Report. We have a number of internal forums which enable engagement on human rights issues with and amongst our employees.

What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?

Employees are able to report any unethical conduct through the Human Resources department, business unit ethics officers, the Ethics and Fraud Hotline, Group Financial Crime Control and the Group Ethics Officer. Reported incidents include all types of financial crime, including issues such as harassment, ethical dilemmas in procurement and abuse of authority. The highest standards of accountability and corporate governance are applied to cases of whistleblowing. Depending on the nature of these incidents, they are resolved either informally through human resources processes or through a management process following an independent and impartial investigation. In South Africa, our customers are able to lodge a complaint through any Private and Business Banking channel as well as public platforms such as Hellopeter.com and social media. Complaints that cannot be resolved at the channel level are escalated to our Service Recovery unit and those requiring further investigation are escalated to a specialist Complaints Resolution Centre. Information gathered from our complaints management process is used to improve service and to track the performance of customer service initiatives. Our ethics and fraud whistle blowing hotline is managed externally by KPMG and all the contact details in South Africa and internationally are communicated on our website, with additional information for staff on an intranet site. [link]

Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?

The Social and Ethics Committee Board approved the Standard Bank Group Human Rights Policy in 2013. Prior, we had already for some time undertaken human rights assessments and assessments for politically exposed or sanctioned individuals as part of our Equator Principles and credit approval processes. High level assessments at country level were also undertaken. Exclusion policies for child labour, etc are in place in credit policies. We function under the South African constitution and legal system which has a Bill of Rights and has fully incorporated the ILO's core conventions into labour law. Standard Bank Group has not signed the Universal Declarations of Human Rights.

We nevertheless strongly believe in upholding the provisions of the UN Universal Declaration of Human Rights; the International Labour Organisation (ILO) Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy; the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises. The Standard Bank Group supports individual human rights and ensures that group policies comply with the South African Constitution and Bill of Rights, codes provided by labour legislation and local charters, (e.g. Employment Equity Act, The Financial Sector Charter) and codes of best practice (e.g. The Code of Banking Practice and the Code of Conduct for Selling of Unsecured Credit). The group’s vision and values, and the code of ethics, are also proof of the bank’s commitment to embed an ethical culture throughout the group. Standard Bank and Liberty are committed to upholding the principles of the Constitution of the Republic of South Africa, the associated Bill of Rights and labour legislation in our South African operations. Outside of South Africa, we operate to similarly high standards. Standard Bank’s values and the code of ethics apply across all bank operations and are an extension of this commitment, which we aim to embed in the behaviour of all our employees.

Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.

The Social and Ethics Board Committee approved the Standard Bank Group Human Rights Policy in 2013. The Policy is closely aligned with the UN Guiding Principles. The Human Capital Executive Committee approved the Standard Bank Group Disability Policy (Employees) in 2014.

What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?

Some of our human rights commitments have been in place for a number of years and are now an integrated part of our business operations, such as the Equator Principles and credit approval processes for activities we finance, as well as our non-tolerance for discrimination in remuneration. Other of our commitments are more recent, and especially where we are dependent on third parties it can lead to a prolonged and at times resource intensive implementation period.