Important information
Slavery and Human Trafficking Statement 2022
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 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
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 annually 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 2021 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 2021 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 2022
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.
Archive: Gender Pay Gap Reports
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 ABG, the Company’s holding company explain the Board’s approach to its stakeholders.
The Directors are conscious that their decisions and actions have an impact on stakeholders. The stakeholders we consider in this regard are our shareholder, Arbuthnot Banking Group PLC (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, Chairman of the Board 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 2021 the Board resolved that the Company should pay a special dividend to replace the final dividend that was withdrawn at the request of the regulators at the outset of the pandemic. This reflected new PRA guidance on the suitability and appropriate level of distributions. The Board also determined that no dividend should be paid in respect of earnings for 2020. This seemed an equitable share of the risks and rewards as the employees of the Group received no bonuses or pay rises in the same year. In seeking to restore this equilibrium in July 2021, by which time the future prospects of the business were more positive, the Board declared a further interim dividend of £2.4m, being broadly equal to that paid in 2019.
The Board decided to maintain significant investment in modern technology in order to grow the Group’s businesses. During the year, it approved further investment in the Bank’s core banking system to ensure that the platform is capable of supporting its future growth and development.
A further illustration of the balancing of the interests of our stakeholders in their long-term interest was the decision in October 2021 to approve an arrangement with a third party, unlocking capital used in both the Bank’s 100% risk-weighted assets and in new commercial investment loans secured on real estate in order to grow towards the “Future State” vision. The Future State is the name given to the Board’s key objective of generating sufficient profits and capital to keep the Bank growing at a good pace whilst making sure employees and shareholders are suitably rewarded, once our capital has been deployed.
Interests of the Company's employees
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 23, 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. Early on in the pandemic, the decision was taken to prioritise job retention and not to furlough any employees, whilst awarding no bonuses for 2020, in order to protect the business. There were regular communications with staff during the year in order to check on their wellbeing and to communicate the intention to reward them for their hard work and dedication over the period with a resumption of bonuses for 2021, following the return to profitability, and on plans for a return to the office. The results of an employee engagement survey conducted over the summer were reported to the Board; this achieved an 89% response rate, 91% of whom were proud to work for the business. The Board also endorsed a new Agile Working Policy, implemented from October, to enable the business and its employees to benefit from a practical combination of office and remote working.
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 during the year providing support where possible, including with a return to meetings in the office between October and mid-December and 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
Following a strategic review of its international representation, the Board concluded that the Dubai office no longer fitted with its future growth plans and so took the decision to close the branch on 31 May 2021. When the office opened in 2013, it represented a good opportunity for the business to build assets under management, but over time opportunities were realised to grow the Company by deploying capital through lending in the UK. The Dubai business generated a good volume of client relationships for the Bank, but its contribution versus its high cost base made it unviable for the Bank’s future growth aspirations. Existing relationships were successfully migrated to the Bank’s London based teams for continued client servicing and our employees were offered equivalent jobs in London.
Impact of the Company's operations on the community and the environment
In September 2021, the Board reviewed a Climate Change Spotlight, noting the initiatives being taken including an Environmental Social and Governance (ESG) project. This was established, given the Bank’s exposure to climate change transition risk as the UK evolves to a low carbon economy through 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 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.
23 March 2022