2022 Communication on Progress

Lloyds Banking Group

Published date

June 29, 2022

No. of questions

54

Supplemental files

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

    1. Does the Board / highest governance body or most senior executive of the company:

    Optional comment
    https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/2021-reporting/lbg-climate-report-2021-interactive-final.pdf - page 49 https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/modern-slavery-human-trafficking-statement-2021.pdf - page 5

    2. Does the company have a publicly stated commitment regarding the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a commitment within 2 years

    Yes, and the commitment is focused on our own operations

    Yes, and the commitment includes our own operations and the value chain

    Yes, and the commitment includes our own operations and the value chain along with communities and society

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/2021-reporting/lbg-esg-report-2021-interactive-final.pdf https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/human-rights-policy-statement-2021.pdf https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/modern-slavery-human-trafficking-statement-2021.pdf

    3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a code of conduct within two years

    Yes, focused on employee conduct

    Yes, focused on employees and suppliers

    Yes, focused on employees, suppliers, and other business relationships

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/220225-lbg-code-of-ethics-2021-interactive.pdf

    4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

    No one is specifically responsible for this topic

    Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)

    Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)

    Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights

    Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    The accountable Executive for the Group’s human rights and modern slavery approach is Janet Pope, the Group’s Chief of Staff and Group Director, Sustainable Business. As part of her role in the Group Executive Committee, she is responsible for championing our Group approach to human rights as well as the publication of our Modern Slavery and Human Rights Policy Statements.

    5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

    No formal structure

    Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)

    Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)

    Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)

    Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Prevention

    6. Does the company have a process or processes to assess risk?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    6.1. During the assessment of risk, which business relationships are reviewed?

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Concerns and grievance mechanisms

    8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

    Optional comment
    Speaking up process (Page 7, https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/220225-lbg-code-of-ethics-2021-interactive.pdf) / Handling disputes, grievances and redundancy (page 9, https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/220225-lbg-code-of-ethics-2021-interactive.pdf)

    8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

    No

    Yes

    Is the process communicated to all employees/workers in local languages?

    Is the process available to non-employees (e.g., contractors, vendors, suppliers)?

    Is the process confidential (e.g., whistleblowing process)?

    Are there processes in place to avoid retaliation?

    Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)

    Other (Please provide additional information)

    Optional comment
    Page 7, https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/220225-lbg-code-of-ethics-2021-interactive.pdf Page 59, https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/2021-reporting/lbg-esg-report-2021-interactive-final.pdf Page 4, https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/working-with-suppliers/third-party-policies/code-of-supplier-responsibility-feb2022.pdf )

    9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

    No process to enable remedy to stakeholders

    Remedy available to some stakeholders (i.e., some geographies, employees only)

    Remedy is available to all affected stakeholders

    Remedy is available to all stakeholders, and suppliers are expected to have similar policies

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Page 7, https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/220225-lbg-code-of-ethics-2021-interactive.pdf Page 59, https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/2021-reporting/lbg-esg-report-2021-interactive-final.pdf Page 1 and following, https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/working-with-suppliers/third-party-policies/code-of-supplier-responsibility-feb2022.pdf )

    Lessons

    10. How does the company capture lessons regarding each of the following sustainability topics?

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

    Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly

    Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Executive Pay

    11. Is executive pay linked to performance on one or more of the following sustainability topics?

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Re Labour Rights we have not made plans but this does not mean this will not happen in the future.

    Board Composition

    12. Percentage of individuals within the company’s Board / highest governance body by:

    Number/Percentage

    Not applicable (Please provide additional information)

    Total number of board members (#)

    10

    Male (%)

    60

    Female (%)

    40

    Non-binary (%)

    We do not disclose non-binary

    Under 30 years old (%)

    0

    30-50 years old (%)

    Our data reports on : 44 to 55 – 40%’, ‘from 56 to 65 – 30%’, and from ’66 to 75 – 30%

    Above 50 years old (%)

    Our data reports on : 44 to 55 – 40%’, ‘from 56 to 65 – 30%’, and from ’66 to 75 – 30%

    From minority or vulnerable groups (%)

    20

    Executive (%)

    77

    Independent (%)

    23

    13. Do you produce sustainability reporting according to:

    Data Assurance

    14. Is the information disclosed in this questionnaire assured by a third-party?

    Page 4 - https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/2021-reporting/final-2021-independent-assurance-statement-by-deloitte-llp.pdf

  • Human Rights

    Materiality / Saliency

    1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?

    Optional comment
    We have plans to identify the Group's salient human rights risks

    Response

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/human-rights-policy-statement-2021.pdf

  • Labour

    Commitment

    1. Does the company have a policy commitment in relation to the following labour rights principles?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    2022

    Forced labour

    2022

    Child labour

    Non-discrimination in respect of employment and occupation

    2022

    Occupational safety and health

    2022

    Working conditions (wages, working hours)

    2022
    Optional comment
    https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/human-rights-policy-statement-2021.pdf

    1.1. For each labour rights policy, is it:

    Aligned with international labour standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving labour rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Plan to develop a stand alone policy

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks /impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    We became a UK Living Wage Employer in 2015 and review our pay rates annually to ensure minimum rates are above the statutory minimum and living wage requirements that are applicable in the countries we operate in. Our current salary minimum is 2 per cent higher than the minimum rate announced by the Living Wage Foundation in November in 2021. We have worked, and continue to work, with third-party contractors to ensure that they operate in line with our commitments and expect them to ensure that the wages they pay meet legally mandated minimum requirements without unauthorised deductions.

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    4. Who receives training for the following labour rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment

    Performance

    6. What is the percentage of employees covered under collective bargaining agreements?

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    99

    7. What is the percentage of employees in a trade union or other workers' organization?

    Percent of employees (%)

    Unknown

    Not applicable (Please provide additional information)

    Employees in a trade union or on a worker committee (%)

    45

    8. In the course of the reporting period, what was the percentage of women in:

    Percent of women (%)

    Unknown

    Senior leadership level position

    37.7

    Non-executive board

    40

    9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

    Salary ratio (%)

    Unknown

    Choose to not disclose

    Women / Men (%)

    29.9

    10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    We do report the total recorded accidents involving injury in our public reporting however we do not report this per hour.

    11. In the course of the reporting period, what was the company’s incident rate?

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    We do report the total number of incidents in our public reporting however we do not report this a rate per employee.

    Response and Reporting

    12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    We do not disclose this information

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    During 2021 the Group has made additional improvements to the Group’s Speak Up programme. We have established a new Group Conduct Investigations team who lead Speak Up investigations across the Group, and manage the Group’s Speak Up framework. In addition, new colleague guides were introduced, helping colleagues navigate the process, and the Group has upgraded its whistleblowing site, making it as accessible and user friendly as possible. The volume and type of concerns reported in 2020 and 2021 were influenced by the COVID-19 pandemic. Colleagues have used Speak Up to escalate their concerns about personal wellbeing, changes to working patterns and to express unease about returning to offices and branches. Such concerns were dealt with through line management or our HR People Partners, to ensure swift and sensitive resolution. In 2021, colleagues reported 352 concerns. 79 were investigated formally, while the remainder were managed through a more appropriate route. 48 per cent of the investigations closed in 2021 were found to be substantiated and resulted in remedial action. Bullying and harassment concerns (including sexual harassment, racial harassment and managerial behaviour) were the most common type of report investigated during 2021, and accounted for 47 per cent of the investigations overall. Where cases were substantiated, appropriate action was taken to rectify the situation - see page 59 https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/2021-reporting/lbg-esg-report-2021-interactive-final.pdf

    13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/modern-slavery-human-trafficking-statement-2021.pdf https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/human-rights-policy-statement-2021.pdf - page 9

  • Environment

    Commitment

    1. Does the company have a formal policy on the following environmental topics?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Climate Action

    2022

    Water

    2022

    Oceans

    Forests / Biodiversity / Land Use

    2022

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    2022

    Energy & Resource Use

    2022
    Optional comment
    https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/2021-reporting/lbg-climate-report-2021-interactive-final.pdf

    1.1. For each environmental policy, is it:

    Aligned with international environmental standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving environmental expertise from inside and outside the company?

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    Our Group-wide sustainability strategy includes ambitious targets and policies across a range of items, in line with the latest climate science, national and international best practice frameworks, and available publicly. For example our Forestry statement can be found within our External Sector Statements on our website. These has also been approved and endorsed at the highest levels within Lloyds Banking Group.

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks/ impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    Specific actions to manage the risks associated with climate and change and energy include, but are not limited to: working to implement the recommendations of the TCFD, and setting financed emissions targets by sector up to 2030, alongside establishing work plans to realise those targets, starting with motor, oil and gas and power - detail of which can be found in the 2021 climate report.

    4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    We have robust targets in place for much of our climate work, including an overall target to halve our financed emissions by 2030, to become Net Zero in our operational footprint by 2030, and to plant 10m trees by 2030 - to support the reforestation of the UK and mitigate the risks that deforestation presents.

    5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Climate Action

    This is not something we report on

    Water

    This is not something we report on

    Oceans

    This is not something we report on

    Forests / Biodiversity / Land Use

    This is not something we report on

    Air Pollution

    This is not something we report on

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    This is not something we report on

    Energy & Resource Use

    This is not something we report on
    Optional comment
    This is not something we report on

    Climate Action

    6. What were the company’s gross global greenhouse gas emissions for the reporting period?

    Scope 1 Emissions

    Emissions (tCO2e)

    37653

    Scope 2 Emissions

    0tCO2e (as above - and note market-based in note column

    Emissions (tCO2e)

    Scope 3 Emissions

    Emissions (tCO2e)

    80404
    Optional comment
    All of these figures and a related explanation can be found within our 2021 Climate Report.

    7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

    Percent of revenue (%)

    Optional comment
    We do not currently quantify the amount invested in the development of low-carbon products and services.

    8. Has the organization acted to support climate change adaptation and resilience?

    Optional comment
    As founding members of the NZBA and as signatories to the TCFD, we are committed to robustly managing the risks and opportunities associated with climate change, in doing so making ourselves and our shareholders more resilient to climate change. In our home insurance business we are doing specific work on resilience, given the increasing prevalence of flooding. This includes working closely with Government and other industry peers on issues like flood defences, and exploring how we can better support our customers to build their resilience in the instance of a flood.

    Energy / Resource Use

    9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

    % of total energy consumption

    69
    Optional comment
    Total Energy (SECR - Elec, Oil, Gas and Road Vehicles Travel) Total Energy (Elec., Gas & Oil) incl. Data Centres (kWh) Total Energy From Road Vehicle Travel Total Energy (Electricity only) Total Renewable Electricity Detail provided on table above

    Technology

    10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

    Percent of total revenue (%)

    While we do not currently report on the revenue linked to low-carbon/ environmentally friendly products, we do have a range of sustainable finance ambitions, as outlined on p.41 of our 2021 Climate Report. These include £15bn of sustainable finance for corporate and instutitional clients by 2024, £10bn of green mortgage lending by 2024, £8bn of financing for electric vehicles and plug-in hybrid vehicles by 2024, ad £20-25bn of discretionary investment in climate-aware investment strategies by 2025, with at least £1bn invested in climate solutions investments.

    Sector-specific Questions

    11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.

    Overall Environment

    21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

    https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/2021-reporting/lbg-climate-report-2021-interactive-final.pdf

  • Anti-corruption

    Commitment

    1. Does the company have an anti-corruption compliance programme?

    https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/group-codes-and-policies/ecp-policy-anti-bribery-statement-of-compliance-may21.pdf

    2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

    Optional comment
    https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/220225-lbg-code-of-ethics-2021-interactive.pdf

    Prevention

    3. Who receives training on anti-corruption and integrity?

    Optional comment
    Anti-corruption and Integrity are modules included in the mandatory training. 97% of the colleagues received mandatory training (page 7 of https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/2021-reporting/esg-datasheet-2021-final.pdf) ''We provide mandatory training and awareness programmes for all our colleagues, including temporary staff and contractors. We also work with third parties acting on our

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

    4. Does the company monitor its anti-corruption compliance programme?

    To help ensure our business is conducted without bribery and corruption, we are committed to: • Conducting regular risk assessments of our business practices to identify, mitigate and

    Response and Reporting

    5. Please report the company's total number and nature of incidents of corruption during the reporting year.

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    NA

    Confirmed during the current year, and related to this year

    NA

    6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

    Pages 2 and 3, https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/group-codes-and-policies/ecp-policy-anti-bribery-statement-of-compliance-may21.pdf -

    7. Does your company engage in Collective Action against corruption?

    We make sure that our Economic Crime Prevention Policy includes the requirements of all relevant laws and regulations, in particular the UK Bribery Act 2010 (which applies to us wherever in the world we operate), the U.S. Foreign Corrupt Practices Act of 1977 and the requirements of our primary regulator, the Financial Conduct Authority', page 1 https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/group-codes-and-policies/ecp-policy-anti-bribery-statement-of-compliance-may21.pdf

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

    We introduced a combined Economic Crime Prevention Policy during the first half of 2021, bringing together the disciplines of fraud, antimoney laundering, anti-bribery and sanctions into one single core policy applicable and mandatory to all business areas. The policy is designed to ensure compliance with the relevant legislation and regulations and sets out the fundamental requirements for business areas to perform which includes risk assessments and implementation of proportionate controls and ensures independent oversight is maintained to assure the efficacy of such controls. The Economic Crime Prevention mandatory training course reflects the key policy requirements and is undertaken annually by all colleagues as part of colleague mandatory training, page 62, https://www.lloydsbankinggroup.com/assets/pdfs/who-we-are/responsible-business/downloads/2021-reporting/lbg-esg-report-2021-interactive-final.pdf ______________________________________________________________