Important information
Slavery and Human Trafficking Statement 2024
This Statement is made pursuant to section 54 of the Modern Slavery Act 2015 (“the Act”) and sets out the steps that Arbuthnot Latham & Co., Limited (Arbuthnot Latham) has taken to ensure that slavery and human trafficking is not taking place in its supply chains or any part of its business or that of its subsidiaries (“AL Group”).
Introduction
Arbuthnot Latham does not tolerate modern slavery or human trafficking within the AL Group’s business operations and is committed to ensuring that its supply chains are free from slavery and human trafficking. This Statement sets out the actions that Arbuthnot Latham has taken and will continue to take, to understand and combat slavery and human trafficking risks within the businesses of the AL Group.
Our business
Arbuthnot Latham is a private limited company registered in England and Wales and is a wholly owned subsidiary of Arbuthnot Banking Group PLC.
Arbuthnot Latham provides private banking, wealth management and commercial banking services, with offices in London, Manchester, Exeter and Bristol. Arbuthnot Latham’s subsidiaries include Renaissance Asset Finance, Arbuthnot Commercial Asset Based Lending Limited, Asset Alliance Group Holdings Limited and Arbuthnot Specialist Finance Limited. The Arbuthnot Latham Group prides itself on quality of service and reputation built on understanding client needs.
In support of our business operations, Arbuthnot Latham purchases goods and services from a number of suppliers, the majority of which are based in the UK.
Our policy on slavery and human trafficking
We have an Anti-Modern Slavery Act Policy, procedures and processes which reflect our commitment to acting ethically and with integrity in all business relationships, and additionally to ensure slavery and human trafficking is not taking place anywhere in our business or supply chains. We also operate a Whistleblowing Policy, which encourages our employees to report any concerns or wrongdoing.
Supply chain risk within Arbuthnot Latham
We operate within a professional and regulated environment and do not have complex supply chains or obtain material services from suppliers with a high risk of slavery or human trafficking. We have adopted a risk-based approach to review existing suppliers and will adopt this approach for any new supplier with which we contract. The Arbuthnot Latham Anti-Modern Slavery Act Policy is available to all existing and potential new suppliers to Arbuthnot Latham. Where applicable, we ensure that our suppliers have a contractual obligation to comply with all applicable laws that apply to their supply of goods and services to us, regardless of the jurisdiction in which they operate.
Due diligence processes for slavery and human trafficking
As part of our initiative to identify and mitigate the risk of slavery and human trafficking, we carry out a risk assessment which will denote the level of due diligence and compliance checks required when engaging and working with suppliers. This ensures that the diligence undertaken is proportionate to the services provided. All of our supplier relationships are reviewed on an annual basis, or biennial, if considered to be ‘low risk’.
Training
Training is fundamental to raising awareness and educating all staff members on the issues highlighted in the Act. We provide relevant training and development for all staff members in order to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and business, and our obligations under the Act. This training is reviewed biennially to ensure that it remains relevant and up to date.
Looking Ahead
We will continue to review and report on the following indicators to assess the effectiveness of our actions:
- The number of employees trained in relation to slavery and human trafficking
- Any non-compliance with the Modern Slavery Act and its requirements.
Conclusion
In 2023 we had no reported incidents of human rights breaches, slavery, or trafficking. We reiterate our commitment to the Act and its underlying principles.
This Statement has been reviewed by key stakeholders and senior management and has been approved by the Arbuthnot Latham Board of Directors. It will be reviewed annually and updated as required.
Approval
This statement is made with respect to the financial year ended 31 December 2023 in accordance with section 54(1) of the Modern Slavery Act 2015. It has been approved by the Arbuthnot Latham Board of Directors and signed by a Director.
Andrew Salmon
Chief Executive Officer
Arbuthnot Latham & Co., Limited
31 March 2024
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Banking
Arbuthnot Latham & Co., Limited considers a dormant bank account to be one which has been inactive for the last two years and where it has not been possible to establish contact with the client. For security reasons we will not send statements to a client who has a dormant account where correspondence has been returned from their last known address. If you have money in a dormant account or lost account, it will always be your property (or if you die, it will become part of your estate). This is the case no matter how many years pass. To enquire about a dormant bank account, please contact our Private Banking Support team on +44 (0)20 7012 2600.
Investment Management
If you believe you have money or assets with Arbuthnot Latham & Co., Limited that are in a dormant or lost account, please call +44(0)20 7012 2500 and ask to speak to a member of the Investment Management team.
Arbuthnot Latham & Co., Ltd (AL) comply with dual-regulated firms Remuneration Code. AL remuneration disclosures are available in the Arbuthnot Banking Group’s(parent company) Pillar 3 disclosures which can be accessed here.
This section of the Strategic Report describes how the Directors have had regard to the matters set out in section 172 (1) (a) to (f) of the Companies Act 2006 when making decisions. It forms the Directors’ statement required by Arbuthnot Latham as a large-sized company under section 414CZA of the Act.
The Directors have acted in a way that they considered, in good faith, to be most likely to promote the success of the Company for the benefit of its members as a whole, and in doing so had regard, amongst other matters, to:
- the likely consequences of any decision in the long term
- the interests of the Company's employees
- the need to foster the Company's business relationships with suppliers, customers and others
- the impact of the Company's operations on the community and the environment
- the desirability of the Company maintaining a reputation for high standards of business conduct and
- the need to act fairly as between members of the Company.
The Arbuthnot Principles set out on page 3 of the Annual Report of Arbuthnot Banking Group PLC, the Company’s holding company, explain the Board’s approach to its stakeholders. Details of how the Directors had regard to the interests of its key stakeholders during the year are set out below.
The Directors are conscious that their decisions and actions have an impact on stakeholders. The stakeholders we consider in this regard are our shareholder, ABG, of which the Company is a wholly owned subsidiary, and its shareholders, our employees, customers, suppliers, regulators and the environment in which we operate.
Likely consequences of any decision in the long term
The Directors make their decisions to ensure that long-term prospects are not sacrificed for short term gain, reflecting the values and support of Sir Henry Angest, the Company’s President and ABG’s majority shareholder, which have proved successful in creating and maintaining shareholder value over many years. This was demonstrated in the year by a number of Board decisions.
In March 2023, the Board gave approval for management to agree terms for a lease on new office premises at 20 Finsbury Circus in the City of London notwithstanding significantly higher costs. The decision was made, taking a long-term view, because the building offers a more flexible and modern working environment which should retain and attract talented staff and enhance the client and staff experience. It would allow the Group to progress with its future growth plans in one location. It will assist the Group in achieving its ESG targets and all London staff would be housed in one location. The Board regarded its decision as a significant step forward, maintaining the Bank’s reputation with its customers and employees, and a statement of confidence in its future.
In July 2023, as part of its as part of succession planning and of its consideration of diversity, the Board appointed Jayne Almond, and Lord Sassoon as non-executive directors with effect from 1 September 2023, subject to satisfaction of applicable regulatory and compliance requirements which was given towards the end of August.
Interests of the Company's employees
As explained above, the decision to move London offices was driven partly by the intention to enhance the staff experience.
Employees are able to raise concerns in confidence with the HR Team, with grievances followed up in line with a specified process which satisfies all legal requirements. Paul Marrow, a non-executive director and chairman of the Risk Committee, has been designated by the Board as the Director to engage with the workforce. He is also the Group’s Whistleblowing Champion and there is an anonymous whistleblowing service via an external provider. There is also protection for employees deriving from the Public Interest Disclosure Act 1998. Any whistleblowing events are reported annually to the Risk Committee and, where material, notified to the Board and to the applicable regulator.
The Board receives an update on human resource matters at each of its meetings. It is also kept informed of the results of employee surveys including one on Diversity & Inclusion conducted in September 2023, which received a 73% response rate. It noted that on most measures the Group scored around 60 to 70 with the exception of the measure of Arbuthnot as an Employer, scoring 87. In November 2023 an engagement survey was launched to focus on other important topics that matter to employees, including their personal growth, wellbeing, communication from senior leaders, reward and recognition as well as the important measure of the Group’s engagement score and the results will be considered by the Board in due course. The Board regards the maintenance of a high level of employee engagement as key to the Company’s future success as an organisation on every level and the focus will be to continue to develop its working environment to achieve this aim.
Company's business relationships with suppliers, customers and others
The Directors attach great importance to good relations with customers and business partners. In particular, our clients are integral to our business and forging and maintaining client relationships are core to Arbuthnot Latham’s business and crucial for client retention. The decision to move offices was driven partly by the intention to enhance the client experience. As regards customers, the Board reviewed the continuing Consumer Duty project, which is overseen by the Risk Committee, from regular reports to it and updates from its Board Champion, Angela Knight.
The Company is committed to following agreed supplier payment terms. There is a Supplier Management Framework in place covering governance around the Company’s procurement and supplier management activities. For due diligence and compliance purposes, suppliers are assessed through an external registration system. The Modern Slavery Statement, approved by the Board in March as part of its annual review of the Company’s stance and approach to the Modern Slavery Act, explains the risk-based approach that the Company has taken to give assurance that slavery and human trafficking are not taking place in its supply chains or any part of its business.
Other stakeholders include the Company’s Regulators, the PRA and the FCA, with whom open and regular dialogue is maintained.
Balancing stakeholder interests
An illustration of the balancing of the interests of our stakeholders in their long-term interest was the Board’s decision in May 2023 to continue its progressive dividend policy. During the year, it resolved to pay two dividends totalling £6,856,000 to its shareholder. This was an increase of 17% from the dividends paid in 2022.
Impact of the Company's operations on the community and the environment
As part of the management information reviewed at its regular meetings, the Board receives a Risk Management report, containing a report on Environmental, Social and Governance (ESG) matters which includes a Climate Change Dashboard, monitoring climate change measures in place including Scope 1, 2 and 3 GHG emissions. This dashboard details climate-change measures and actions.
The Board is updated on the steps the Group is taking to become more sustainable, given its exposure to climate change transition risk as the UK evolves to a low carbon economy. It is also kept informed of the formal approach to ESG established to develop over time, which will underpin the Arbuthnot Principles and Values within the workplace under five pillars of sustainability – governance, clients, employees, community and environment (ESG Pillars). The ESG actions taken are in recognition of the Group’s responsibility to make a positive societal impact and the political, regulatory and legal pressure with clients and investors in ABG increasingly interested in the Group’s ESG stance.
In September 2023 the Board approved the enterprise-wide climate change risk appetite, risk assessments, and stress test scenarios and results. It also considered climate change risk in major change decisions, including in the case of the planned 2024 London premises relocation initiated this year.
Desirability of the Company maintaining a reputation for high standards of business conduct
The Directors believe that the Arbuthnot culture set out in the Arbuthnot Principles on page 3 of ABG’s Annual Report manifests itself at Board level and in the external view of the Group as a whole. The critical importance of the Company’s continuing good reputation is considered at each Board meeting. These Principles are encapsulated in five Group cultural values, themselves embedded into day-to-day activities. These values are integrity, respect, empowerment, energy and drive, and collaboration.
27 March 2024