Slavery and Human Trafficking Statement 2023
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”).
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.
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 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 no less than an annual basis.
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.
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.
In 2022 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.
This statement is made with respect to the financial year ended 31 December 2022 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.
Chief Executive Officer
Arbuthnot Latham & Co., Limited
31 March 2023
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.
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 February 2022, the Board considered a number of options to manage the capital resources of the Group, without slowing its lending plans as the divisions build towards the “future state” strategy. This was necessary because of the reintroduction by the Financial Policy Committee of the Bank of England of the countercyclical capital buffer at 1% from December 2022 with a further increase to 2% in July 2023. As a consequence, a decision was taken to allocate capital away from non-core assets and accordingly to sell the Group’s long leasehold West End office property situated at 20 King Street in July with completion in October.
In February 2022, as part of its planning for the future, the Board approved the appointment of Sir Nigel Boardman as Chairman, subject to regulatory approval, in succession to Sir Henry Angest. In July 2022, it appointed Sir Henry President, as permitted by the Company’s Articles of Association, with effect from the date on which Sir Nigel’s appointment was approved by the regulators.
Also in July 2022, the Directors endorsed the decision of the Remuneration Committee to approve a one-off payment to all executive directors and employees in the Group of £1,500 in order to assist them with the increased costs of living being experienced. It was determined that the payment would be reduced pro rata to part time employees and for those who had been with the business less than one year. The Directors were able to agree to this payment of c. £1m, having assured themselves that the business had the resources to make it because of its trading considerably in excess of the planned budget.
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 30, 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 which received a 76% response rate. In November it considered the results of an engagement survey, launched to assess how engaged employees felt with the business, obtaining feedback on key areas that affect engagement including Leadership, ‘My Manager’, Wellbeing, Cultural Values, Diversity & Inclusion, Reward & Recognition and employees’ views in relation to 2022 ways of working and effectiveness of the Agile Working approach which was established and endorsed by the Board in 2021 to enable the business and its employees to benefit from a practical combination of office and remote working. The Agile Working Policy resumed at the end of February 2022 with all employees normally having to work in the office for a minimum of three days per week. This followed its suspension in mid-December 2021 with the introduction of temporary working arrangements in light of the Government’s request in response to the Omicron variant that where individuals can work from home they should do so.
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. Regular contact was maintained with clients throughout the year, including the resumption of meetings in the office again since February 2022.
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 July 2022 to return to its progressive dividend policy, resolving to pay an interim dividend of £2,550,000 to ABG, its shareholder. This was an increase of £150,000 from the normal interim dividend paid in 2021. This decision followed the removal of restrictions on the ability of banks to pay dividends.
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. 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, employees, community, environment and clients (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.
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.
29 March 2023