Policies and legal

  • Site Privacy Policy

    10 Oct 2023

    Your privacy is important to The Bank of London Group Limited ("The Bank of London", "we", "us" and "our"). We are committed to protecting your personal data and being transparent about the personal data we hold and use and, wherever possible, giving you control over how we use your personal data. Privacy and data protection are an integral part of our systems and services. The Bank of London and maintains a number of security measures to protect your personal data. These include data access controls with respect to personnel of The Bank of London and clients of The Bank of London including two factor authentication, encryption of confidential and personal data, monitoring, data loss prevention controls and Information Technology (“IT”) security policies. Your personal data is backed up in different locations and audit logs record user and system activities, exceptions, and information security events. Our personnel undergo regular data protection training and are required to adhere to data protection, confidentiality, and IT security policies and our third-party service providers are bound by contractual obligations with regards to data protection, confidentiality, and IT security.

    1. INTRODUCTION

    This notice applies to any individual associated with a client or prospective client of The Bank of London which includes partners, directors, shareholders, beneficial owners, company secretaries, trustees, members and employees and to anyone whose personal data we process in connection with the provision, or possible provision, of services by us to our clients ("you" and "your") including as a result of communications and interactions with us, through the use of our services directly or indirectly (including processing payments) and as necessary in order to enable us to comply with our legal and regulatory obligations (for example by carrying out verification, anti-money laundering, and sanctions checks). Please read this notice carefully. Among other things, it explains:

    • WHAT PERSONAL DATA we may collect about you in connection with: (i) our delivery of, and your use of our website, software, systems and the provision of our transactional and agency products and services (including use of The Bank of London Website, The Bank of London Portal and The Bank of London API) together the "Services"; and (ii) any related interaction between you and us;

    • HOW AND WHY WE PROCESS YOUR PERSONAL DATA and the lawful basis or bases by which we process your personal data and other important information, such as how long we retain your personal data and who we share your personal data with; and

    • YOUR RIGHTS in relation to the personal data we hold about you. We may collect, use, disclose and store information about you when:

      • you interact or use The Bank of London website The Bank of London: Home ("Website"), The Bank of London Portal and/or The Bank of London API;

      • you correspond with us;

      • you register for or use any of the Services including indirectly through a client of ours and as a result of making or receiving a payment that is processed by us;

      • your employer or a business that you are associated with or with whom you are contracted to, registers for or uses any of the Services (a "Related Entity");

      • we carry out ongoing diligence, monitoring and screening, or respond to an external inquiry, in respect of anti-money laundering, politically important persons, source of wealth, fraud, sanctions and other crimes;

      • you report an error in or request technical support for The Bank of London Portal or The Bank of London API or generally request any client support;

      • you make a complaint; and/or

      • you provide data for other legal and regulatory purposes.

    This notice is intended to be communicated to you in a concise, transparent, intelligible, and easily accessible manner, but we appreciate that you may have queries or want to seek clarification as to its terms. If so, please contact us (using the details set out at section 2 below) and we will endeavour to respond to you as soon as possible.

    We may make changes to this notice from time to time, including as may be necessary or prudent to reflect any changes in the ways in which we process personal data or any changes in data protection laws. Any changes and updates to this notice will be posted on The Bank of London Website ( The Bank of London: Home ). Please check this notice regularly so that you are aware of any changes.

    2. WHO WE ARE AND OUR CONTACT DETAILS

    We are The Bank of London Group Limited (or "The Bank of London", but we may also use “TBOL”, "we", "us", or "our" to refer to The Bank of London throughout in this policy). The Bank of London is a company registered in England and Wales under registered number 12844788. Our registered address is at 100 Bishopsgate, City of London, EC2N 4AG, United Kingdom. We are a bank authorised by the Bank of England’s Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Bank of England’s Prudential Regulation Authority under Financial Services Register number: 930379. For the purposes of data protection laws The Bank of London usually operates as the data controller. For some processing activities required in the provision of The Bank of London Services (including the processing of transactions), we will be a joint controller with our client which might be a Related Entity. In other activities, we may be a processor, acting on the specific instructions of a client or third party which might be a Related Entity.

    Categories of Data

    Description of Data

    Identity Data

    Name, address, date of birth, age, marital status, title, maiden name, gender, nationality, country of residence, driving licence, birth certificate, marriage certificate, national ID card, passport and other identification documents (including utility bills, national insurance number, social security number, tax number, residence permit, payslips or other), job title, role, directorship, shareholding, employer, company/organisation name and details on a business card or in an email signature, Curriculum Vitae, education details, socio-demographic details, details regarding sanctions and whether you are a politically exposed person or a family member of a politically exposed person.

    Contact Data

    Email address, address, telephone number, mobile number, other information in an email signature.

    Financial Data

    Bank account details, account number, sort code, your financial position, assets, income, salary details, source of wealth information.

    Transaction Data

    Payment transaction details, account number, sort code, payment amount and any information contained in a payment reference.

    Correspondence Data

    Information which you provide in, or we learn about you from, any correspondence or communications with us, including details of any enquiries or requests for technical support and any complaints.

    Usage Data

    Device IP address, the pages of The Bank of London website that you visit, usage information for The Bank of London website and The Bank of London Portal.

    Security Data

    Username, password, security word and hint, memorable word.

    Technical Data

    Type of device, unique device identifier (e.g. an IMEI number, IP, or Mac address), network information, the type of operating system and browser you use, time zone settings and other device related information.

    Publicly Available Data

    Details obtained from online searches or that is otherwise available in public records including identity data, socio-demographic data, financial and economic data, data obtained from the electoral register and Companies House.

    Marketing and Communications Data

    Your marketing preferences and communication preferences.

    For further information regarding when we process your personal data as a joint controller and with whom, or as a processor, please contact us. For information regarding how a Related Entity processes your personal data, please contact that relevant Related Entity. If you have any queries regarding this notice or the way in which we process your personal data, please contact us at:

    Email: DataProtectionOfficer@thebankoflondon.com

    Address: For the Attention of the Data Protection Officer, The Bank of London Group Limited, 100 Bishopsgate, City of London, EC2N 4AG, United Kingdom.

    3. CHANGES TO YOUR PERSONAL DATA

    It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes or if you become aware that any personal data that we hold is not accurate.

    4. WHAT PERSONAL DATA WE COLLECT

    4.1 The type of personal data we process may include (as applicable) the following: Information about why we process, and the lawful basis upon which we rely to process, the above personal data is set out in the table at section 5 below.

    4.2 We may process special categories of personal data (also known as sensitive personal data) including details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. This data may be transferred to us without our knowledge including in a payment reference or obtained by us for the purposes of our money laundering and verification checks (for example, within data that reveals political opinions). We may also process information about criminal convictions and offences including terrorist offences and fraudulent activity. Such information is recorded by us and may be shared with financial crime prevention agencies, law enforcement agencies, regulators, and other financial institutions.

    4.3 We may collect personal data from you directly and we may also obtain personal data from third parties or public sources including the following:

    4.3.1 A Related Entity or a client of ours;

    4.3.2 Third parties engaged by a Related Entity or a client of ours;

    4.3.3 Financial Institutions, payment service providers, payment system operators and other financial services companies (to (amongst other things) provide The Bank of London Services, process a payment and prevent, detect and prosecute fraudulent and criminal activity);

    4.3.4 LexisNexis (a third party company engaged by us to carry out identification and money laundering checks);

    4.3.5 Credit reference agencies;

    4.3.6 Law enforcement and fraud prevention agencies;

    4.3.7 Regulatory and government bodies such as the Prudential Regulation Authority, Financial Conduct Authority, HM Revenue and Customs, the Bank of England, National Crime Agency;

    4.3.8 Companies House;

    4.3.9 Public registers;

    4.3.10 Third party websites; or

    4.3.11 External legal counsel and other professional advisors.

    5. THE PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL DATA

    5.1 We use your personal data for a number of purposes but only where we are allowed to by the law.

    5.2 We may process your personal data in any circumstances where such processing is necessary:

    5.2.1 in order to perform any agreement we have entered into with a Related Entity or a client or otherwise as necessary in the provision of The Bank of London Services, including to process a transaction;

    5.2.2 to comply with any applicable law or regulation; and/or

    5.2.3 for the purposes of the legitimate interests pursued by us or a third party. These legitimate interests include the purposes identified in the table below at paragraph 5.7 but also include other commercial interests and our internal administrative purposes. Where we rely on legitimate interests as the lawful basis for processing your personal data, we will put in place appropriate safeguards to protect your data and to ensure that your interests or fundamental rights and freedoms are not overridden by those legitimate interests.

    5.3 We may also process your personal data where we have your consent which may be obtained for us by a Related Entity. Where we rely on consent as the lawful basis for processing your personal data, you have the right to withdraw your consent at any time and if you wish to do so, you should contact our Data Protection Officer using the contact details set out in paragraph 2 above. Where we obtain your consent to send you marketing communications, you can unsubscribe by following the unsubscribe link within the communication. The withdrawal of consent does not affect the lawfulness of processing based on consent before withdrawal or the lawfulness of processing based on other lawful grounds.

    5.4 We may process special categories of personal data and data relating to criminal convictions and offences where:

    5.4.1 we have your explicit consent;

    5.4.2 the processing is necessary for reasons of substantial public interest because of the law; and/or

    5.4.3 the processing is necessary for the establishment, exercise, or defence of legal claims.

    5.5 We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

    5.6 We may process your personal data ourselves or in conjunction with our third-party service providers in accordance with paragraph 7.

    5.7 Information about the purposes for which we use your personal data, the types of personal data we process to achieve these purposes, and the lawful basis by which we process it, is set out in the table below:

    Purpose / Activity

    Types of Personal Data Processed

    Lawful Basis for Processing

    Registration

    To register a client or register a user to The Bank of London Portal.

    Administration purposes

    Identity Data

    Contact Data

    Financial Data

    Correspondence Data

    Usage Data

    Security Data

    Technical Data

    Publicly Available Data

    Marketing and Communications Data

    Consent

    Performance of a contract

    Compliance with a legal obligation

    Our legitimate interests to operate our business, provide The Bank of London Services and fulfil our legal and contractual obligations

    5.8 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

    5.9 If we need to use your personal data for an unrelated purpose, we will notify you (which may be by way of update to this notice) and we will explain the legal basis which allows us to do so.

    5.10 Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

    6. WHAT IF YOU REFUSE TO PROVIDE US WITH ANY PERSONAL DATA?

    6.1 Where we need to collect personal data by law, or under the terms of an agreement we have with you or a Related Entity, and you fail to provide that data when requested (or fail to consent to the processing of that data, if necessary), we may not be able to perform the agreement or arrangement we have or are trying to enter into with a Related Entity.

    7. SHARING INFORMATION WITH THIRD PARTIES

    7.1 We will not share any of your personal data with third parties except as set out in this paragraph 7 or otherwise notified to you or agreed between you and us from time to time.

    7.2 We may share personal data with our group companies (including our subsidiaries, ultimate holding company and its subsidiaries) and partnered companies for the purposes outlined in this notice. We may also share personal data with third party service providers who we engage to provide services which facilitate our business and we may need to share personal data with other third parties in order to comply with our legal and regulatory obligations. Below is a list of specific third parties and other categories of third parties with whom we may share your personal data:

    7.2.1 A Related Entity or a client of ours;

    7.2.2 A third party engaged by a Related Entity or a client of ours;

    7.2.3 LexisNexis;

    7.2.4 DocuSign;

    7.2.5 Finteza, operated by MetaQuotes Ltd, our provider of online marketing tools;

    7.2.6 Jumio, our identity verification provider;

    7.2.7 Credit reference agencies;

    7.2.8 The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found here;

    7.2.9 Financial institutions, payment system operators, payment service providers and other financial services companies;

    7.2.9 External legal counsel and other professional advisers including accountants and auditors;

    7.2.10 Regulatory and government bodies such as the Prudential Regulation Authority, Financial Conduct Authority, His Majesty’s Revenue and Customs (HMRC), the Bank of England, National Crime Agency and other law enforcement and fraud prevention agencies; and

    7.2.12 any similar or replacement third parties from time to time.

    7.3 We ensure that any third party engaged by us who processes your personal data in connection with the purposes listed in paragraph 5 has policies and procedures in place to ensure compliance with data protection laws.

    7.4 For any third parties that are based, or process data, outside of the United Kingdom, we engage such third parties in accordance with paragraph 8 below.

    7.5 We will remain the controller responsible for the processing of your personal data notwithstanding that third parties may operate as a joint controller with us. For some processing activities we may act as a processor for a third party and, in such circumstances, the third party will be responsible for providing you with the processing information required under data protection laws.

    7.6 We may share your personal information with third parties where we are required to do so by law or regulation (such as in connection with an investigation of fraud or other legal enquiry) or in connection with other legal proceedings (including where we believe that your actions violate applicable laws or any agreement with us).

    7.7 In the event that our business or any part of it is sold or integrated with another business, your details may be disclosed to our advisers and those of any prospective purchaser and will be passed to the new owners of the business.

    8. INTERNATIONAL TRANSFERS OF PERSONAL DATA

    8.1 From time to time it may be necessary for us to transfer your information internationally including to fulfil your request, process a transaction, or otherwise as required in the provision of The Bank of London Services. In particular, your information may be transferred to and/or stored on the servers of third parties identified in paragraph 7 which are based outside of the UK and the EEA.

    8.2 However, we will not transfer your personal data outside of the United Kingdom unless:

    8.2.1 such transfer is to a country or jurisdiction which the United Kingdom has approved as having an adequate level of protection;

    8.2.2 appropriate safeguards are in place in accordance with data protection laws. These safeguards can include the use of standard contractual clauses or binding corporate rules;

    8.2.3 any data importer provides us with relevant sources and information relating to the destination country or territory and the laws applicable to the transfer in that destination country in order to substantiate the matters set out in 8.2.1; or

    8.2.4 the transfer is otherwise allowed under data protection laws (including where we have consent, the transfer is necessary for important reasons of public interest, is necessary for the establishment, exercise or defence of legal claims or is necessary for the performance of a contract with the data subject).

    8.3 We will ensure that where your personal data is transferred outside of the United Kingdom, the data importer will be contractually obliged to:

    (a) ensure your personal data it is afforded the same protection as would be afforded to it within the United Kingdom; and

    (b) keep us informed of any development affecting or likely to affect the level of protection your personal data receives in the importer’s country.

    9. YOUR RIGHTS AS A DATA SUBJECT

    9.1 Subject to any conditions and requirements set out in data protection laws, you may have some, or all, of the following rights in relation to the personal data we hold about you:

    9.1.1 the right to request a copy of your personal data held by us;

    9.1.2 the right to correct any inaccurate or incomplete personal data held by us;

    9.1.3 the right to request that we erase personal data we hold about you;

    9.1.4 the right to request that we restrict the processing of your data;

    9.1.5 the right to have your personal data transferred to another organisation;

    9.1.6 the right to object to certain types of processing of your personal data by us; and

    9.1.7 the right to complain (please see paragraph 13 of this notice).

    9.2 Please note that these rights are not absolute in all situations and may be subject to conditions and provisions set out in data protection laws. We cannot, therefore, guarantee that we will be able to honour any request from you in connection with the rights set out above. (For example, even if you request that we delete your personal data, we may be required by law to retain some personal data for accounting and record keeping purposes or in order that we comply with our legal and regulatory obligations.)

    9.3 For further information, or to exercise any particular right, please contact us at DataProtectionOfficer@thebankoflondon.com

    10. STORAGE AND RETENTION OF YOUR PERSONAL DATA

    10.1 As a minimum, we need to store your personal data for as long as is necessary to enable us to fulfil the purpose for which it is processed, including to fulfil our legal and regulatory obligations (e.g. relating to record keeping) and to exercise or defend any legal claims.

    10.2 We maintain and implement a data retention policy and will delete personal data in accordance with this.

    10.3 For as long as we do store your data, we follow generally accepted industry standards and maintain reasonable safeguards to attempt to ensure the security, integrity, and privacy of the information you have provided. All information you provide to us is stored on our secure servers. We have implemented a risk assessment framework that is based on the principle of ISO31000 and the NIST Framework.

    10.4 It is important that you keep secure and confidential any login credentials that you have for The Bank of London Website and/or The Bank of London Portal. You are responsible for maintaining the security and confidentiality of such login credentials. You should notify us promptly if you become aware that the security or confidentiality of your login credentials is compromised.

    10.5 We will notify you without undue delay in accordance with the requirements of data protection laws, if we have reason to believe that there has been a personal data breach by us which could adversely affect your rights and freedoms and we are required by law to notify you.

    11. LINKS TO THIRD PARTIES

    11.1 The Bank of London Website may link or redirect to other websites, social media accounts or other content which is not under our control. Such links or redirections are not endorsements of such websites or representation of our affiliation with them in any way and such third-party websites are outside the scope of this notice.

    11.2 If you access such third-party websites, please ensure that you are satisfied with their respective privacy policies before you provide them with any personal data. We cannot be held responsible for the activities, privacy policies or levels of privacy compliance of any website operated by any third party.

    12. COOKIES

    12.1 The Bank of London Website uses some cookies as detailed in our Cookie Policy.

    13. QUESTIONS AND COMPLAINTS

    13.1 We take our data protection obligations seriously. If you have any questions or complaints about this notice or the way that we handle your personal data, we would appreciate the chance to deal with your concerns in the first instance before you approach the relevant data protection authority. Please contact us at uk.complaints@thebankoflondon.com.

    13.2 You have the right to make a complaint at any time to any relevant supervisory authority for data protection issues, including, in the United Kingdom, the Information Commissioner's Office (ICO) (www.ico.org.uk)

  • Site Terms of Use

    30 MAR 2023

    This website(s) (www.thebankoflondon.com) is an official website(s) of The Bank of London Group Limited (“Website”).

    You should read these terms and conditions (“Terms”) carefully before using this Website. Using the Website indicates that you accept these Terms regardless of whether or not you choose to register with us. If you do not accept these Terms, do not use this Website. 

    1. WHO WE ARE

    We are The Bank of London Group Limited (or "The Bank of London", but we also use “TBOL”, "we", "us", or "our" to refer to The Bank of London throughout the Website). The Bank of London is a company registered in England and Wales under registered number 12844788. Our registered address is at 100 Bishopsgate, City of London, EC2N 4AG, United Kingdom. 

    We are a bank authorised by the Bank of England’s Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Bank of England’s Prudential Regulation Authority under Financial Services Register number: 930379.

    To contact us, please email us at: contactus@thebankoflondon.com.

    2. INTRODUCTION

    You may access most areas of the Website without registering your details with us. Certain areas of the Website are only open to you if you register. By accessing any part of the Website, you shall be deemed to have accepted these Terms in full. If you do not accept these Terms, you must leave the Website immediately. We will revise these Terms from time to time, and you should periodically check the Website to review the then current Terms because they are binding on you.

    Certain provisions of these Terms may be superseded by expressly designated legal notices or terms located on particular pages of the Website. Where you have registered for additional services (for example Internet Banking or Mobile Services) you may also be subject to additional Terms and Conditions. 

    3. CONTENT

    Unless otherwise stated, the copyright, trademarks, and other intellectual property rights in all material on the Website (including without limitation text, tools, photographs and graphical images) are owned by us or our licensors.

    You may not reproduce or adapt the Website in whole or in part without our prior written consent, except for the purpose of accessing our products and/or services and for producing print outs for your own personal and non-commercial purposes. No part of the Website may be reproduced or stored in any other website or included in any public or private electronic retrieval system or service without our prior written permission.

    Any use of the Website other than in accordance with these Terms is prohibited. If you breach any of these Terms, your permission to use the Website automatically terminates and you must immediately destroy any downloaded or printed extracts from the Website.

    Any rights not expressly granted in these Terms are reserved.

    4. SERVICE ACCESS

    While the Website is normally available 24 hours a day, we shall not be liable if for any reason the Website is unavailable at any time. Access to the Website may be suspended temporarily and without notice in the case of system failure, maintenance, or repair or for reasons beyond our control.

    5. VISITOR MATERIAL AND CONDUCT

    Other than personally identifiable information, which is covered under our Privacy Policy, any material you transmit or post to the Website shall be considered non-confidential and non-proprietary. We shall have no obligations with respect to such material. We shall be free to copy, disclose, distribute, incorporate, and otherwise use such material and all data, images, sounds, text, and other things embodied in them for any and all commercial or non-commercial purposes.

    You must not post or transmit to or from the Website any material: (a) that is threatening, defamatory, obscene, indecent, seditious, offensive, pornographic, abusive, liable to incite racial hatred, discriminatory, menacing, scandalous, inflammatory, blasphemous, in breach of confidence, in breach of privacy or which may cause annoyance or inconvenience; or (b) for which you have not obtained all necessary licenses and/or approvals; or (c) which constitutes or encourages conduct that would be considered a criminal offence, give rise to civil liability, or otherwise be contrary to the law of or infringe the rights of any third party, in any country in the world; or (d) which is technically harmful (including, without limitation, computer viruses, logic bombs, Trojan horses, worms, harmful components, corrupted data or other malicious software or harmful data). You may not misuse the Website (including, without limitation, by hacking).

    We will co-operate fully with any law enforcement authorities or court order requesting or directing us to disclose the identity or locate anyone posting any material in breach of these Terms.

    6. LINKS TO AND FROM OTHER WEBSITES

    Links to third party websites on the Website are provided solely for your convenience. If you use these links, you leave the Website. We have not reviewed all these third-party websites and do not control and are not responsible for their content or availability. We do not endorse or make any representations about them, or any material found there. If you decide to access any of the third-party websites linked to the Website, you do so entirely at your own risk.

    If you would like to link to the Website, you may only do so on the basis that you link to, but do not replicate, the home page of the Website, and subject to the following conditions: (a) you do not remove, distort or otherwise alter the size or appearance of the any images or logos; (b) you do not create a frame or any other browser or border environment around the Website; (c) you do not in any way imply that the we are endorsing any products or services other than our own; (d) you do not misrepresent your relationship with us nor present any other false information about us; (e) you do not otherwise use any trademarks displayed on the Website without our express written permission; (f) you do not link from a website that is not owned by you; and (g) your website does not contain content that is distasteful, offensive or controversial, infringes any intellectual property rights or other rights of any other person or otherwise does not comply with all applicable laws and regulations. We expressly reserve the right to revoke the right granted in this clause for breach of these Terms and to take any action deem appropriate. You shall be responsible for any loss or damage suffered by us for breach of this clause.

    7. REGISTRATION

    Where you are invited to register for any part of this Website, each registration is for a single user only. You must not share your username and password with any other person or with multiple users. Responsibility for the security of any passwords issued rests with you.

    8. DISCLAIMER

    This Website is here to give you information about our products and services. It is up to you to decide whether they are suitable for you. 

    The information on the Website may not tell you all you need to know, and you can ask us or an independent financial advisor for more details.

    Though we try and keep the information up to date, there may be a time delay before we can do so. You should not rely solely on the information on this Website. You should check details about important things like price or interest rates in any actual agreement you sign as it is the terms in that document that form the agreement between us.

    9. OUR AND YOUR LIABILITY FOR USE OF THIS WEBSITE

    The Website only complies with English only. You may not always be able to access this Website. We are not responsible for any losses if you cannot do so (for example if you cannot obtain a product at a stated price). We are not responsible if the means of communication you use to access the Website or to send us information about yourself or to receive information from us does not work properly.

    As we’ve explained above, the information on this Website may not always be quite up to date or complete. We advise you to check it carefully before you agree to buy a product or service, and we are not responsible for any losses you suffer if you fail to do so unless what we put on the Website was incorrect or misleading (and provided the correct information was not provided to you or made available before you completed your purchase).

    Whilst we take reasonable care to ensure the accuracy of information on third party websites (outside The Bank of London group of companies) which we may have linked through this Website, as we cannot control what they contain, we are not responsible for any losses or other damage you suffer as a result of using those other websites.

    We are not liable for losses or costs caused by abnormal and unforeseeable circumstances outside our reasonable control, which would have been unavoidable despite all efforts to the contrary, for example delays or failures caused by industrial action, problems with another system or network, third party viruses or malware, mechanical breakdown, or data-processing failures.

    Please remember that email is not a completely secure means of communication: it may be possible for others to intercept and read your messages. So, if you choose to send us information by email, it is at your own risk.

    10. GOVERNING LAW AND JURISDICTION

    These Terms shall be governed by and construed in accordance with English law. Disputes arising in connection with these Terms shall be subject to the exclusive jurisdiction of the English courts.

  • Site Cookie Policy

    4 AUG 2022

    Below is information about how The Bank of London (“we”) use cookies and other similar technology on this website.

    1. OVERVIEW

    Our Cookie Policy should be read in conjunction with our Privacy Policy. We will update both policies from time to time.

    Your privacy is important to us, so we currently only use a small number of cookies to continuously improve our website and your browsing experience. Some cookies are also essential for our website’s basic functionality.

    We can place cookies and other similar technology on your device, including mobile device, in accordance with your preferences set on our Cookie Consent Manager.

    2. WHAT ARE COOKIES?

    Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a site and allow a site to recognise your device. Cookies managed by The Bank of London only are called “first party cookies” whereas cookies from third parties are called “third party cookies” as explained below.

    3. WHY DO WE USE COOKIES AND SIMILAR TECHNOLOGIES?

    Cookies do a lot of different jobs, such as letting you navigate between pages efficiently, remembering your preferences and generally improving the user experience.

    4. WHAT COOKIES DO WE USE?

    We currently use a small number of cookies to continuously improve our website and your browsing experience. Some cookies are also essential for our website’s basic functionality.

    • Essential cookies: these are cookies without which our website cannot function. They help you access our website and each of its web pages by enabling basic functions like setting cookies. You may disable these by changing your browser settings, but this may affect how the website functions.

    • Non-essential cookies: we need your permission to hold and use these. For example, we use a third party service, Finteza, that helps assess the behavioural patterns on our website. By collecting visitors’ internet log information (such as IP address and type of browser) we can track the number of visits to each section of our website. This helps us improve the design of our website and its functionality. Please note, we do not make any attempt to find out the identities or nature of those visiting our website.

    This policy describes in more detail how you can manage your cookies, the types of cookies we use and why we use them. You will always have the option to prevent some cookies from being stored, however, this could impact your experience.

    Our website, The Bank of London and each of its web pages use two types of cookies:

    • Session cookies: these are temporary cookies that are stored only while you are browsing our website and are removed as soon as you close the browser. We use them to provide you with a better experience, for example, to avoid the re-entry of information.

    • Persistent cookies: These remain on your device even after you exit our website. We use them to recognise you when you come back and to remember your preferences. We can also use them to manage the traffic on our website efficiently and to improve your experience on our website. We store these for a maximum of 90 days.

    5. THIRD PARTY COOKIES

    Session and persistent cookies can be either first or third party cookies. A first-party cookie is set by us, whilst a third-party cookie is provided by a third party that is providing a particular service.

    We use Finteza, a web analytics service provided by MetaQuotes LTD.The cookies used by Finteza help us to analyse how users use the website and to count the number of people who use the website. We will anonymise your IP address so that Finteza will store only an anonymised version from which you are not identifiable. However, please note that Finteza may transfer any data obtained through the use of Finteza to the US in order to balance its server usage. The US does not afford the same level of legal protections as are available in the United Kingdom, and in accepting our use of Finteza you are acknowledging that your anonymised IP address may be transferred to the United States.

    The list below summaries all the cookies that we use.

    Cookie Preferences (CookieConsent) 

    • Type: Essential, third-party 

    • Description: This cookie is set by our website because we use CookieBot, our cookie law compliance solution. It is set after you have seen a cookie information notice and only when you actively close the notice down. It enables our website not to show the message more than once.  This cookie is required by the IAB Europe Transparency & Consent Framework to store the user's consent.

    • Retention period: The cookie has a 90 day lifespan and contains no personal information.

    Cookie Preferences (Cookiesession1)

    • Type: Essential, third-party 

    • Description: This cookie is also set by the cookie compliance solution from Cookiebot. It stores information about the categories of cookies the site uses and whether you have given or withdrawn consent for the use of each category. This enables us to prevent cookies in analytics categories from being set in the users browser, when consent is not given. It contains no information that can identify the site visitor.

    • Retention period: The cookie has a 90 day lifespan, so that returning visitors to the site will have their preferences remembered.

    Finteza(_fz_uniq) 

    • Type: Non-essential, third-party performance (analytics)  

    • Description: This cookie is associated with Finteza Analytics and is used to distinguish unique users. It is included in each page request in a site.

    • Retention period: The cookie has a 90 day lifespan, so that returning visitors to the site will have their preferences remembered.

    Finteza(_fz_ssn) 

    • Type: Non-essential, Third-party performance (analytics)  

    • Description: This cookie is associated with Finteza Analytics and is used to distinguish unique users’. session and campaign data for the sites analytics reports.

    • Retention period: The cookie has a less thank one day, session only lifespan, so that analytics for that session can be captured.

    Finteza(_fz_fvdt) 

    • Type: Non-essential, third-party performance (analytics)  

    • Description: This cookie is associated with Finteza Analytics and is used to remember information about a visitor to the site.

    • Retention period: The cookie has a 90 day lifespan, so that returning visitors to the site will have their preferences remembered.

    Finteza(_fz_gtd)

    • Type: Non-essential, Third-party performance (analytics)

    • Description: This cookie is associated with Finteza Analytics and is used to distinguish unique users’ session and campaign data for the sites analytics reports.

    • Retention Period: The cookie has a less than one day, session only lifespan, so that analytics for that session can be captured.

    Finteza(tr)

    • Type: Non-essential, Third-party performance (analytics)

    • Description: This cookie is associated with Finteza Analytics and is used to remember information about a visitor to the site.

    • Retention Period: The cookie has a less than one day, session only lifespan, so that analytics for that session can be captured.

    reCaptcha (_GRECAPTCHA) 

    • Type: Essential, third-party 

    • Description: This cookie is set by our website because we use reCaptcha by Google to prevent automated attacks against our site.

    • Retention period: The cookie has a less than one day, session only lifespan.

    DataDog(_dd_s) 

    • Type: Non-essential, Third-party performance (analytics)  

    • Description: This cookie is associated with DataDog and is used to distinguish unique users’ session and campaign data for the sites analytics reports.

    • Retention period: The cookie has a less than 4 hour, session only lifespan, so that analytics for that session can be captured.

    DataDog(dd_site_test_*) 

    • Type: Non-essential, Third-party performance (analytics)  

    • Description: This cookie is associated with DataDog and is used to test the browser for cookie support.

    • Retention period: The cookie expires instantly once the testing is complete.

    DataDog(dd_cookie_test_*) 

    • Type: Non-essential, Third-party performance (analytics)  

    • Description: This cookie is associated with DataDog and is used to test the browser for cookie support.

    • Retention period: The cookie expires instantly once the testing is complete.

    Google Analytics(_ga)

    • Type: Non-essential, Third-party performance (analytics)

    • Description: This cookie is associated with Google Analytics and is used to distinguish users who visit our site.

    • Retention Period: The cookie has a retention period of 2 years.

    Google Analytics(_ga_VXCPEW7T5X)

    • Type: Non-essential, Third-party performance (analytics)

    • Description: This cookie is associated with Google Analytics and is used to persist session state.

    • Retention Period: The cookie has a retention period of 2 years.

    We regularly audit our cookie usage to ensure that we have a full list and share accurate information with you in this policy. However, it is possible we may have missed one from our list above. If you happen to find one that is being set on our site, please let us know.

    6. MANAGING YOUR COOKIES

    With your consent, we store non-essential cookies on your device. You can change your cookie preference at any time through the settings on your browser. This enables you to remove stored cookies by deleting them from your browser history (cache) when you leave our website. You can find more information about cookies, including how to control the use of these through your browser settings, at www.allaboutcookies.org or www.aboutcookies.org. We may revise this cookie policy at any time by amending this page. Please check it from time to time to take notice of any changes we may make.

  • Tax Statement

    13 SEPT 2022

    The Bank of London conducts business ethically, honestly, fairly, and transparently. How we conduct ourselves is critical to our success. We strive to maintain and adhere to the highest standards of governance and ethical conduct in everything we do.

    Our commitment to ethical behaviour and conduct means that we abide by not only the letter, but also the spirit of applicable acts of Parliament and regulation and, in particular, with regard to our tax planning and strategy. As such, we’ll always pay tax in line with both the requirements and the spirit of all acts of Parliament.

    1. WE DON’T ENGAGE IN ARTIFICIAL TAX PLANNING

    We believe artificial tax planning is wrong. We’ll only enter into transactions to support commercial activities – we won’t engage in artificial tax planning for the sake of cutting or avoiding the paying of tax.

    2. WE PROTECT VALUE

    We want to provide great value for our shareholders, stakeholders, our clients, and their customers. One of the ways we achieve this is by minimising our costs through effective tax management, meaning such things as claiming lawful reliefs and incentives where it is permissible to do so – but only in line with the intentions of the law and the spirit in which relevant acts of Parliament were passed.

    3. WE ACT WITH DUE CARE

    Given the impact tax can have on our company, shareholders, and stakeholders, we’ll be diligent in how we manage all our tax-related processes by reviewing everything through clear reporting lines and making any changes we need via these structures. Both our Group Board and United Kingdom Board receives monthly updates as to our compliance with tax laws and regulations, so oversight over our tax strategy goes all the way to the top.

    4. WE MANAGE RISK

    Tax law and regulation can be complicated. So, can running a bank. This means we may run into tax issues from time to time. We’ll make sure we have the right policies, systems, and procedures in place to manage these and ensure we’re paying the right amount of tax.

    5. WE WORK WITH THE RIGHT PEOPLE

    In the spirt of ensuring we pay the right amount of tax, rather than employing a large or complex in- house tax team, we work alongside our external advisors to manage our tax position and keep it compliant.

    6. WE ARE TRANSPARENT

    We adopt His Majesty’s Revenue & Custom’s (“HMRC”) voluntary Code of Practice for banks and seek to collaborate openly and honestly with them. We endeavour to be proactive in our all our discussions with HMRC and strive to meet any deadlines they may set.

    7. STATEMENT APPROVAL

    This statement was approved by the Group Board of Directors and the United Kingdom Board of Directors in November 2021 and confirm this statement fulfils its obligations under the Finance Act 2016; Schedule 19, Paragraph 22(2).

  • Anti-Modern Slavery Statement

    1 DEC 2021

    1. OVERVIEW

    The Bank of London conducts business ethically, honestly, fairly, and transparently. How we conduct ourselves is critical to our success. We strive to maintain and adhere to the highest standards of governance and ethical conduct in everything we do.

    This statement is made pursuant to section 54 of the United Kingdom’s Modern Slavery Act 2015 and sets out the steps that The Bank of London take to ensure that modern slavery or human trafficking does not occur within our business or our supply chain.

    Modern slavery encompasses slavery, servitude, human trafficking and forced labour. The Bank of London has a zero-tolerance approach to any form of slavery and trafficking. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within our business or our supply chain.

    This is The Bank of London’s first anti-modern slavery and human trafficking statement. It explains what we have done so far; what measures we have in place to prevent it; and next steps. As we develop our plans further, we will update this statement too.

    2. WHO WE ARE

    We are The Bank of London Group Limited (or "The Bank of London", but we may also use “TBOL”, "we", "us", or "our" to refer to The Bank of London throughout in this statement).

    The Bank of London is a company registered in England and Wales under registered number 12844788. Our registered address is at 100 Bishopsgate, City of London, EC2N 4AG, United Kingdom.

    We are a bank authorised by the Bank of England’s Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Bank of England’s Prudential Regulation Authority under Financial Services Register number: 930379.

    3. OUR POLICIES ON MODERN SLAVERY AND HUMAN TRAFFICKING, DUE DILIGENCE AND RISK MANAGEMENT

    We are committed to preventing modern slavery or human trafficking in our business and our supply chains. For us, good business and ethics go hand in hand.

    Our current policies are:

    OUR PEOPLE: We are committed to a workplace culture that reflects our values of diversity, fairness, compassion, and non-discrimination. Our staff is recruited legally, and we comply with the United Kingdom’s Immigration Act 1998. We have a whistleblowing policy in place and a whistleblowing champion.

    OUR CUSTOMERS: To ensure our clients and their customers are protected against modern slavery:       

    • We assess our clients’ applications against our ethical statement and conduct due diligence in line with our anti-money laundering policy.

    • We will end relationships with clients if there are indicators or concerns about modern slavery or trafficking and report it to the authorities (National Crime Agency following a Suspicious Activity Report).

    • We have financial crime teams made up of subject matter experts, which will investigate any suspicious activity or risk in this field.

    • We train our staff extensively. All new hires undertake mandatory training on economic crime, conduct risk and anti-money laundering. Specialist teams, such as the risk and compliance team and customer service team, undertake additional training including on customer due diligence, complying with sanctions, and fighting fraud. The client services teams are trained on identifying and supporting vulnerable customers and referring them to third party experts who can assist them.

    OUR MARKETPLACE PARTNERS: We expect partners to adhere to The Bank of London’s standards. We request a copy of the anti-modern slavery statement for our largest Marketplace partners, both at onboarding and as part of annual due diligence review.

    4. OUR SUPPLIERS

    The Bank of London utilises services from third parties predominantly located in the United Kingdom, United States and European Union. To tackle slavery and trafficking in our supply chain we:

    • Incorporate anti-slavery obligations into agreements with suppliers where relevant and on a risk-assessed basis.

    • Adopt a risk-based approach in identifying, monitoring, and assessing suppliers who are at a greater risk from instances of slavery and trafficking taking appropriate mitigating actions.

    • Perform due diligence and relationship oversight in line with the Supplier & Outsourcing Policy and Third-Party Management Procedure, ensuring Vendors meet The Bank of London’s expectations on an ongoing basis.

    • We will work with the government, regulators, and law enforcement to help identify and tackle modern slavery and human trafficking.

    • Compliance with all applicable laws, including modern slavery, forms part of our contract that we look to put in place with key suppliers. The Bank of London will only deal with third parties where we are satisfied the third party operates in a manner consistent with The Bank of London’s core values.

    5. LOOKING AHEAD

    As this is our first statement, there is more that we can do. In the next few months, we will develop a more comprehensive anti-modern slavery statement, increase our training, and strengthen our processes where necessary.

    6. STATEMENT APPROVAL

    This statement was approved by the Group Board of Directors and the United Kingdom Board of Directors in November 2021.

  • Apolitical Statement

    13 SEPT 2022

    1. MANAGING POLITICAL ACTIVITIES

    The Bank of London conducts business ethically, honestly, fairly, and transparently. How we conduct ourselves is critical to our success. We strive to maintain and adhere to the highest standards of governance and ethical conduct in everything we do.

    Our commitment to ethical behaviour and conduct means that we abide by not only the letter, but also the spirit of applicable acts of Parliament and regulation and, in particular, with regard to political activities to prevent against bribery, corruption or reputational risks associated with political activities. We do not compromise on the legal, regulatory or policy requirements that govern our activity.

    2. POLICY AND PROCEDURES

    Political activities cover contributions, engagement with public officials through advocacy, and the recruitment of staff from the Public Sector (‘Revolving Door’). The Bank of London ensures that any political activities it engages in are confined to legitimate advocacy on matters relevant to The Bank of London, its clients and the banking industry. The Bank of London will ensure that its advocacy activities are not, and cannot be perceived to be, seeking to secure any form of improper business advantage or influence governmental actions for The Bank of London. This includes complying with its Bribery Act Policy, its financial crime obligations and adhering to all applicable governmental laws, policies, and guidance governing interactions with public and governmental officials.

    Consequently, The Bank of London seeks to embed the requisite policies and controls to ensure that its employees (including permanent employees, fixed term contractors, directors, and non-executive directors) globally understand these obligations and abide by them. The same applies to any other party with whom we do business, whenever they act for or on behalf of The Bank of London. All employees are specifically required to comply with our Global Policy Framework, which sets out our framework for managing potential risk to our organisation.

    Our overall approach is framed around and based on the values of integrity, legitimacy, materiality, consistency, accountability, and oversight. Our policies, procedures and systems are specifically designed to meet these values, acts of Parliament and regulations, shareholder, and stakeholder expectations. The ways in which we manage the associated risk of our political engagements include:

    Identifying and managing memberships of organisations The Bank of London engages in advocacy;

    • An integrated approach to all aspects of political activities;

    • Conducting a regular risk assessment to identify, control and mitigate associated risks;

    • Performing monitoring and assurance activity to identify potential concerns;

    • Transparency in all matters.

    3. POLITICAL CONTRIBUTIONS

    The Bank of London is an apolitical organisation with a standing policy of not making contributions to any political party. Donations (financial or in kind) to political parties, individuals or campaigns are not permitted on its behalf.

    4. ADVOCACY

    Earning our clients’ trust includes understanding the impact of government policy to ensure our products and services are right for our clients (and their customers) and meet legal and regulatory requirements. As a result, we may be invited to participate in government consultations and policy discussions to share our industry expertise and perspective and to inform their deliberations.

    Any engagement with governments or policymakers is typically conducted alongside financial institutions and other corporate and non-corporate organisations operating in the United Kingdom (UK). The Bank of London will engage with governments (UK and devolved), parliamentarians and policymakers at executive and working levels. We respond to public consultations from a range of public organisations, such as His Majesty’s Treasury (HM Treasury), the Prudential Regulatory Authority (PRA), the Financial Conduct Authority (FCA), accept invitations to appear before select committees and parliamentary groups, and participate in joint task forces to outline our insights and perspective on industry matters.

    5. THIRD PARTIES

    The Bank of London is a member of several trade associations as part of its involvement in consultation on local, national UK, European Union, and United States legislation. Ensuring that The Bank of London’s active and comprehensive representation on trade associations is crucial as part of understanding upstream risks. Our Director of Corporate Affairs & Community Engagement works closely with employees and non-executive directors to identify representation that The Bank of London should pursue to ensure and that we are actively engaged where required and that we manage associated risks.

    When engaging with any third party, intermediary or partners, we require compliance with all applicable local and national laws, and where appropriate applicable The Bank of London policies and procedures, to ensure they are acting in an ethical and lawful manner – always.

    6. RECRUITMENT

    The Bank of London has controls in place to manage the exchanges of people between the public sector and The Bank of London through the recruitment process (including secondments). An assessment of the risk posed is undertaken and any mitigating controls imposed (such as cooling off periods), if required.

    To the extent that The Bank of London decides to hire an individual who is or has been affiliated in any way with the public sector and/or political parties (“Relevant Individual”), it will conduct prior due diligence and vetting on the Relevant Individual. This due diligence will include obtaining disclosure of the Relevant Individual’s significant commitments and business interests they have outside of their proposed role in The Bank of London so that The Bank of London is able to assess potential conflicts of interest between it and the Relevant Individual. This due diligence will be in addition to the information collated and requested by The Bank of London in accordance with its obligations under the Prudential Regulatory Authority’s (PRA’s) and Financial Conduct Authority’s (FCA’s) Senior Managers & Certification Regime

    Where the Relevant Individual has worked in a UK ministerial office or in the Crown’s service in the last 2 years, The Bank of London will seek confirmation that the Relevant Individual has applied for and obtained advice in accordance with Government Guidance from the Advisory Committee on Business Appointments and has complied with all applicable guidance issued by this body(1).

    In addition, the service agreement or employee contract entered by the Relevant Individual will contain provisions which require the Relevant Individual to inform The Bank of London in advance of any changes to significant commitments or business interests. In certain circumstances, the Relevant Individual may be required to seek approval from The Bank of London before accepting further commitments or entering into business interests which either might give rise to a conflict of interest or a conflict with any of the Relevant Individual’s duties to The Bank of London.

    The Relevant Individual will also be required to disclose to The Bank of London any actions which could reasonably be expected or lead to unwanted or unfavourable publicity to The Bank of London.

    7. ACCOUNTABILITY

    Responsibility for the co-ordination and oversight of political activity – including monitoring, analysis, and development of policy positions, legislative responses, and engagement with political and legislative stakeholders (including through events and one-to-one meetings) rests with The Bank of London’s Director of Corporate Affairs & Community Engagement. (1) Business Appointments - making applications under the Rules for former ministers and senior Crown servants - GOV.UK (www.gov.uk).

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