Anti-Bribery and Corruption
Our bank promotes an ethical business culture with the highest level of integrity and one that does not tolerate the use of bribery in any aspect of our business operations. We have established policies and procedures that are designed to comply with the expectations of applicable anti-bribery legislation in the markets and jurisdictions in which we operate such as the UK's Bribery Act 2010 and the Financial Crime section of the FCA Handbook.
We expect our directors, employees, third party service providers, and business partners/suppliers to behave ethically at all times in carrying out their respective functions or when performing any form of service on our bank’s behalf.
Conflict of Interest
Our bank engages in a variety of activities in the delivery of our products and services. Due to the nature of these activities, situations where the bank’s interests conflict with those of other stakeholders’ may arise from time to time. In these circumstances, we take all appropriate steps to prevent or appropriately manage such conflicts while ensuring our customers are treated fairly.
Insider Trading
Our bank is committed to maintaining the integrity of financial markets and protecting the general public from market abuse, which includes insider dealing and market manipulation. We have established safeguards to prevent and detect these offences, including a whistleblowing framework wherein such violations can be formally reported.
Fair Dealing – Related Party Transactions
Our bank endeavors to ensure that all our transactions, particularly those entered into with our related parties, are legal, ethical, and do not compromise our stakeholders’ value.
We have established policies, procedures, and controls that ensure related party transactions are dealt at an arm’s length basis (i.e., a transaction between two related parties is performed as if these parties were unrelated so as to avoid any conflict of interest).
Whistleblowing
Our bank fosters an environment where our people feel safe to raise reportable concerns and where these concerns are taken seriously.
We have formal channels where our employees can raise a concern, the first of which is through their direct manager, who can immediately act on the concern raised or escalate the matter to the appropriate unit.
In cases where our employees are not comfortable raising a concern through their manager, they also have the option to communicate the concern directly to other members of Senior Management, particularly the Head of Human Resources and the Managing Director.
When an employee prefers to retain his/her anonymity, he/she may also report the concern to an electronic mailbox dedicated to receive whistleblowing reports. Sole access to this mailbox is restricted to the bank’s Whistleblowing Champion.
We ensure all concerns raised are handled with utmost confidentiality and investigated independently, and that whistleblowers are not subject to any form of retaliation.
Voluntary Modern Slavery and Human Trafficking Statement
At BPI Europe, we are committed to upholding the highest standards of ethics and integrity in all aspects of our operations. While our organisation does not meet the turnover threshold required to publish a modern slavery statement under Section 54 of the UK Modern Slavery Act 2015, we believe it is our responsibility to take a proactive stance against modern slavery and human trafficking.
Our Commitment
We maintain a strict zero-tolerance approach to all forms of modern slavery and are committed to conducting our business in a lawful, transparent, and ethical manner. Modern slavery — including human trafficking, forced labour, and exploitation — has no place in our business or supply chains.
Policy Framework
Our internal Modern Slavery and Human Trafficking Policy applies to all staff, management, and counterparties. It is designed to:
- Promote awareness and understanding of modern slavery risks;
- Ensure all employees understand their responsibilities to identify, prevent, and report modern slavery and human trafficking;
- Prevent exploitation within our operations and business relationships.
The policy is aligned with the principles of the UK Modern Slavery Act 2015 and guides our ethical conduct in dealings with customers, suppliers, and third parties.
Governance and Reporting
BPI Europe has established clear governance and reporting mechanisms to support the effective implementation of our policy:
- All employees are responsible for upholding the policy, conducting appropriate due diligence, and reporting any suspicions of modern slavery and human trafficking.
- The Board of Directors provides overall oversight of the bank’s anti-slavery and human trafficking policies and ensures that ethical considerations are embedded in our governance.
- Senior Management, led by the Head of Compliance & AML, is responsible for operationalising and regularly reviewing the policy to maintain its effectiveness.
- Training and Awareness: All staff are introduced to the bank’s policy as part of the employee onboarding process. We also provide regular training on modern slavery and human trafficking, reinforcing awareness of associated risks and the importance of proactive reporting.
We encourage employees to report any concerns through established internal channels, including to the Head of Compliance, the Managing Director, or via our whistleblowing email, which is monitored by the Whistleblowing Champion. All reports are handled confidentially, with sensitivity, and in accordance with our investigation procedures.
Looking Ahead
Although we are a small financial institution, we recognise the importance of contributing to the global effort to eliminate modern slavery. BPI Europe is committed to reviewing and enhancing our internal practices, training, and risk controls to ensure that we continue to operate in line with our ethical values and legal responsibilities.
Diversity, Equality, and Inclusion Statement
At BPI Europe, we are proud of our unique cultural identity and our roots in the Filipino community. As a UK-regulated institution, we are fully committed to upholding the principles of diversity, equality, and inclusion (DEI) in line with the Equality Act 2010 and the expectations of the Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA).
We believe that fostering an inclusive environment—where individuals from all backgrounds feel respected, valued, and empowered—is essential to our success and integrity. Our DEI policy applies to everyone connected to our organisation: directors, employees, contractors, customers, and third-party partners. It guides how we operate, serve, and support people across all aspects of our business.
We are committed to:
- Promoting fair and equal treatment for all, regardless of age, disability, gender, race, ethnicity, religion or belief, sexual orientation, gender identity, marital or civil partnership status, pregnancy or maternity, or any other protected characteristic under UK law.
- Basing employee recruitment, onboarding, progression, and promotion ultimately on merit, capability, and performance.
- Ensuring our workplace is inclusive, free from discrimination, harassment, bullying, and victimisation.
- Delivering services that are respectful, culturally sensitive, and accessible to all communities we serve.
- Embedding DEI principles into our culture, governance, decision-making, and day-to-day operations.
Everyone at BPI Europe shares responsibility for upholding these commitments. Through training, leadership, and open dialogue, we continue to build a culture that champions dignity, fairness, and opportunity for all.