Slavery and Human Trafficking Statement 2020
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 and commercial banking services, with offices in London, Manchester, Exeter, Bristol and Dubai. Arbuthnot Latham’s subsidiaries include Renaissance Asset Finance, Arbuthnot Commercial Asset Backed 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 a 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 Modern Slavery Act Policy is available to all existing and potential new suppliers to Arbuthnot Latham. Where applicable, contractual provisions will be included in agreements or terms of business with suppliers, which are reviewed at least on an annual basis.
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 appropriate due diligence when engaging and working with suppliers, whilst also ensuring that the diligence undertaken is proportionate to the services provided.
Training is fundamental to raising awareness and educating all staff members on the issues highlighted in the Act. We therefore 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.
We reiterate our ongoing 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 2019 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
30 March 2020
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.
From 2019 directors of large companies, such as Arbuthnot Latham, are required to publish a statement explaining how they have performed their duty under section 172 of the Companies Act 2006 to have regard to a range of factors when making decisions. This statement describes how the Directors have had regard to the matters set out in section 172 (1) (a) to (f) and forms the Directors’ statement required under section 414CZA of the Companies Act 2006.
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 stakeholders we consider in this regard are our shareholder, our employees, our customers, our suppliers, our regulators and the environment in which we operate.
The Arbuthnot Principles and Values 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.
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. As an example, this was demonstrated in the year by the decision to make further significant investment in modern technology to grow the Group’s businesses, the cost of which is likely to some extent to precede the benefits in the Income Statement. A further illustration of the balancing of the interests of our stakeholders in the long term interest of the Company is dividend policy where the Board approved dividends to its shareholder in the context of its decisions on capital allocation.
Interests of the Company’s employees
Mr. Marrow, the Group’s Whistleblowing Champion, has been designated by the Board as the Director to engage with the workforce. The Board receives an update on Human Resources matters at each of its meetings. The Employee Survey undertaken in the year showed high engagement and positive responses with 83% of employees proud to work for Arbuthnot Latham. To make the Company a better place to work, the following key themes were identified through the survey results and comments: Reward and Recognition; Employee Wellbeing; Communication; and IT. Each of these themes has been and will be an area of focus.
The workforce is able to raise concerns in confidence to the HR Team, with grievances followed up in line with a specified process which satisfies all legal requirements. Additionally, there is an anonymous whistleblowing service via an external provider. There is also protection for employees deriving from the Public Interest Disclosure Act 1998. Whistleblowing events are notified to the Board and to the applicable regulator.
Our people are a vital asset and the Board is committed to ensuring all staff are treated fairly and with respect. Staff were asked for suggestions for what the Company could do to demonstrate its commitment to diversity and inclusion. A consistent message was to review Maternity/Adoption and Paternity Pay, as a consequence of which an enhanced policy was implemented and communicated to staff.
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 customers are central to our business and forging and maintaining client relationships are core to Arbuthnot Latham’s business and crucial for client retention. As clients’ needs and expectations are changing, meaningful relationships with their bankers are more important than ever. Clients now demand access to their bank and relationship managers through a variety of channels and expect efficient and streamlined processes supported by state of the art technology. Accordingly, during 2019 a decision was taken to invest in the adoption of modern and integrated Client Relationship Management (CRM) technology with the potential to improve significantly front-office operations and help us support our existing and new clients better.
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 Board has adopted a Modern Slavery Statement which sets out the steps 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. During the year, the Directors held their regular meetings with the PRA Supervisory team. The Board also received and considered feedback, following the PRA’s review of the Group’s risk governance and ILAAP and the Periodic Summary Meeting.
Impact of the Company’s operations on the community and the environment
As a financial services company our impact on the environment is limited. Nevertheless, there is growing consensus that an orderly transition to a low-carbon economy will bring structural adjustments to the global economy which will have financial implications, bringing both risks and opportunities. Accordingly, in November the Board adopted a Climate Change Framework, reflecting the PRA’s expectation.
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 and Values 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. It was encouraging in this respect when the Bank won the City A.M. Bank of the Year Award in November 2019.
Acting fairly as between members of the Company
The Company is a wholly owned subsidiary of ABG and so this factor is not relevant to the Directors’ decision-making.
25 March 2020