Important information
Slavery and Human Trafficking Statement 2025
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. All of our supplier relationships are reviewed on an annual basis, with a level of due diligence that is proportionate to the services provided.
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 2024 we had no reported incidents of human rights breaches, slavery, or trafficking. We reiterate our commitment to the Act and its underlying principles.
Review
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 2024 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 2025
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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 1 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.
As part of its as part of succession planning, the Board appointed Frederick Angest and Kevin Barrett as new directors, subject to satisfaction of applicable regulatory and compliance requirements which were subsequently met.
In September 2024, the Board approved the Company’s Diversity, Equity & Inclusion strategy which is based on Arbuthnot’s Seven Principles. These Principles are central to the way the Company works, summarising its corporate philosophy and ethics, and it seeks to ensure that all of its businesses act consistently with them. The approach to Diversity, Equality and Inclusion is therefore holistic, embedded in the Arbuthnot culture and delivered through its cultural values, rather than being as a standalone activity.
Interests of the Company's employees
Overall the Board’s intention is to hire the best people and to provide the right environment for them to perform to the best of their ability.
The decision made in the prior year to move London offices was driven partly by the intention to enhance the staff experience. 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. In November 2024 it considered the results of the engagement survey, launched in September 2024 to assess how engaged employees felt with the business, obtaining feedback on key areas that affect engagement. The engagement survey received an 91% response rate from employees, with an 85% engagement score including 92% agreeing with the statement of being proud to work for the Group. 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 continue to be to develop its working environment to achieve this aim.
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. As explained in the Directors Report on page 18, following the retirement of Paul Marrow, Jayne Almond, a non-executive director, has been designated by the Board as the Director to engage with the workforce. Furthermore Richard Gabbertas, chairman of the Board Risk Committee, is now 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.
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 Board’s decision in the prior year to move offices, confirmed with the approval of the change of registered office from 12 August 2024, was driven also partly by the intention to enhance the client experience. As regards customers, the Board considered the first formal submission of a Consumer Duty annual assurance report from the Chief Compliance Officer, together with a verbal report 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 2024 to pay a dividend of £6,528,000 to its shareholder, ABG, in recognition of the recent strong performance of the Group which made it appropriate for its shareholders to receive an extra payment. This decision was made after the Board had satisfied itself that forecasts showed the Company having sufficient liquidity and capital. In total, during the year, the Board resolved to pay two dividends totalling £16,260,000 to its shareholder. This was an increase of 137% from the dividends paid in 2023.
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 Risk Committee 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.
During the year, ahead of any likely future decisions required, the Board received a presentation from Asset Alliance Group’s Strategic Development Manager on the planned strategy to facilitate a move away from a diesel-based HGV fleet to offering alternative solutions for its customers, based on their needs and operations.
In September 2024 the Board Risk Committee approved the enterprise-wide climate change risk appetite, risk assessments, and stress test scenarios and results.
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 1 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.
26 March 2025