Close Brothers Group anti-slavery and human trafficking statement for the financial year ended 31 July 2016
Close Brothers Group (the “Group”) is a leading merchant banking group providing lending, deposits taking, wealth management services and securities trading.
Close Brothers was established in 1878 and today employs over 3,000 staff, operating principally in the UK and Ireland. Close Brothers Group plc is listed on the London Stock Exchange and is a member of the FTSE 250.
The Group is comprised of three divisions – Asset Management, Securities and Banking, the latter being the biggest and contributing over 90% to the Group’s profits.
Close Brothers’ Banking division, comprising Close Brothers Limited and its subsidiaries, provides specialist lending to small and medium-sized businesses and individuals across a diverse range of asset classes, and also offers deposit taking services.
The Group’s Securities division provides trading services in the UK through Winterflood, a leading market-maker offering execution services to retail brokers and institutional clients.
Close Brothers Asset Management provides a range of financial advice, investment management and online investing services to private clients and professional advisers
The Group is a financial services provider, and therefore has reasonably straightforward supply chains with most of its suppliers based in the UK and EU.
Policy and principles
Close Brothers is committed to complying with its obligations under the Modern Slavery Act and other relevant legislation relating to the detection and prevention of modern slavery. In particular, Close Brothers is committed to implementing and enforcing effective systems and controls that seek to ensure that modern slavery is not taking place anywhere in its business or in its supply chains.
Consistent with its obligations under the Modern Slavery Act, Close Brothers is committed to ensuring there is transparency in its own business and in its approach to tackling modern slavery throughout its supply chains. Close Brothers expects the same standards from its contractors, suppliers and other business partners.
Actions taken in financial year ended 31 July 2016
During the financial year ended 31 July 2016, Close Brothers took the following steps with the intention of ensuring that slavery and human trafficking does not take place in its business or supply chains:
1 .Group Modern Slavery Policy
A new Group Modern Slavery Policy was introduced. The policy applies to all Group companies, divisions and businesses, and their respective permanent and fixed-term employees, temporary staff and contractors.
2. Risk assessments
Risk assessments were undertaken on a prioritised and proportionate basis to identify areas of potential risk in relation to modern slavery and human trafficking among existing suppliers.
3. Procurement due diligence processes
Standard procurement tendering and due diligence processes for larger supply arrangements were amended to reflect the requirements of the Modern Slavery Act.
4. Standard contractual documentation
New contractual provisions requiring suppliers to comply with the Modern Slavery Act have been introduced for use in contracts with suppliers.
5. Employee training
Training and guidance on the Group’s obligations in relation to modern slavery has been provided to targeted employees involved in procurement and the management of supplier relationships.
During the financial year ended 31 July 2016, much of the Group’s focus in this area has been on activities affecting procurement for Group-wide and Banking division supplier relationships. To the extent it has not been done already and where relevant, the Group intends to roll-out equivalent actions in its Securities and Asset Management divisions in the future in a prioritised and proportionate manner.
This statement is made with respect to the financial year ended 31 July 2016 in accordance with section 54(1) of the Modern Slavery Act 2015. This statement covers Close Brothers Group plc, Close Brothers Holdings Limited, Close Brothers Limited, Winterflood Securities Limited, Close Asset Management Holdings Limited and Close Asset Management Limited (each a “Group Company”) and has been approved by the Board of Directors of Close Brothers Group plc and each other Group Company. The statement will be reviewed and updated (if necessary) annually to reflect Close Brothers’ ongoing commitment to ensuring that its business and supply chains are free from slavery and human trafficking. The statement is signed by a director of Close Brothers Group plc, the holding company of the Close Brothers Group.
Chief Executive, Close Brothers Group plc
30 January 2017