In this section, we summarise some of the most important considerations for creating a survivor bank account programme and promoting financial inclusion. You can learn more in the specific modules under the Advance Financial Empowerment chapter. Where further modules exist, these are highlighted below.
The financial mindset of a survivor can be severely impacted by their previous exploitation. This can make it more difficult for an individual to manage their finances and build long-term financial independence.
Working closely with survivor support organisations can help banks to better understand the customers they are onboarding, to satisfy traditional KYC standards. Once established as a partner, banks can ask survivor support organisations to assess the suitability of survivors based on their stage of healing and financial mindset, to ensure that they are ready to open an account. This can help to prevent the misuse of banking products and to better protect survivors from further exploitation.
Find out more about the impact of modern slavery on a survivor’s financial mindset, under section 2 of Financial literacy education.
Staff training on trauma-informed work
Trauma-informed work is essential for financial institutions to promote survivor financial inclusion and support survivors towards long-term independence.
The importance of trauma-informed work applies at every touchpoint between survivors and the bank, from the way that a survivor is treated when they first attempt to open a new account to the delivery of longer-term financial empowerment initiatives.
Recommendations for financial institutions:
- Take time to acknowledge how trauma may affect the emotions and behaviours of survivors (among other vulnerable customers).
- Strive to do no further harm by ensuring that all support is provided in a way that is respectful of the survivor’s need for safety, respect and acceptance. This includes avoiding asking any questions about a survivor’s background or past experience.
All customer-facing employees, regardless of employment, should receive training to understand modern slavery and its long-term effects on survivors. This will help to facilitate survivor financial empowerment by ensuring that the bank is a safe, comfortable and confidential environment for survivors.
Find out more about trauma-informed work within the module ‘Employee training and protecting vulnerable customers.’
Flagging survivor bank accounts
When developing a survivor bank account programme it is important to consider how you will flag these accounts, to protect survivors from harm and provide tailored support.
The advantages of flagging survivor bank accounts are that it facilitates:
- Enabling specific protections for survivors and enhanced monitoring to prevent exploitation.
- Providing tailored guidance and trauma-informed support.
- Recording the number of survivor bank accounts opened.
- Ensuring that survivors are not required to repeat sensitive or traumatic information to explain their situation.
- Adapting follow-up communications to ensure they are appropriate for survivors.
Giving survivors the choice for their account to be flagged has been expressed as a preference by multiple survivors:
“If survivors are identified when they go to their bank to open [an] account, then [they will] be able to offer tailored services to suit them.”
Emma, Survivor Consultant
If suspected exploitation or financial abuse is detected, financial institutions need to provide support and understanding of a survivor’s financial circumstances.
Improving survivor accessibility
Improving accessibility is key for all vulnerable customers and excluded groups, including survivors of modern slavery. Learnings can be taken from a variety of existing initiatives including those which support homeless account holders, customers with learning disabilities or other conditions, such as those with dementia.
Some of the key barriers to consider include:
- Misinformation among survivors.
- Documentation barriers.
- Immigration status.
- Previous account misuse.
- Negative experiences with financial institutions.
- Language barriers and unavailability of interpreters.
- Physical accessibility.
- Data poverty and digital literacy skills.
For further information on recommendations to help improve survivor accessibility head to our next module, Improving Survivor Accessibility.
Tracking outcomes and measuring your impact
From a research, monitoring and reporting point of view, it is helpful for banks to track the number of survivor accounts they are opening. Flagging survivor bank accounts can help to facilitate this. As part of the FAST Survivor Inclusion Initiative, banks are also supported to track the number of referrals made by survivor support organisations in comparison to the number of accounts opened. This helps to monitor and identify any barriers.
Banks can benefit from accurate reporting on survivor bank account opening to feed into their vulnerability, inclusion and modern slavery statements.
“There is a real onus on how many survivor accounts you are opening and that’s something we put in our modern slavery statement.”
Charlotte Davis, Social Sustainability Manager, Lloyds Banking Group
Raising awareness of available products for survivors
Internally, it can be useful for banks to refer to a “survivor bank account”, for monitoring and protection purposes. However, for survivors, it is beneficial to externally remove the “survivor” label from available bank accounts. This can help survivors to move forward with their lives, ensuring that they aren’t limited by a label and can provide confidentiality of an individual’s lived experience.
Where banks are supporting survivors without signposting a dedicated “Survivor Bank Account”, it is important that they are partnering with survivor support organisations to help signpost the products available to survivors and clearly explain what is required to open an account.
“[Survivors] feel like they’ve been included in an institutional universe that was otherwise inaccessible. Many survivors have felt unwelcome by systems such as schools, medical providers, employers and government agencies but, through the Survivor Inclusion Initiative, the financial sector has said ‘come on in’ and accepted them as customers.”
Sarah Byrne, Attorney, Moore & Van Allen