Modern Slavery Act 2015

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and sets out the steps the Company has taken during the financial year from 1 August 2024 to 31 July 2025 to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business.

Group overview

Close Brothers is a leading UK merchant banking group providing lending, deposit taking and securities trading. We employ approximately 3,000 people, principally in the United Kingdom and Ireland. Close Brothers Group plc is listed on the London Stock Exchange.

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 and human trafficking. We are committed to implementing and enforcing effective systems and controls that seek to ensure that modern slavery is not taking place anywhere in our business or in our supply chains. Consistent with our obligations under the Modern Slavery Act, the group is committed to ensuring there is transparency in its own business and in its approach to tackling modern slavery throughout its supply chains. We expect and request the same standards from our contractors, suppliers and other business partners. We maintain a Group Modern Slavery Policy as well as a Group Third Party Management Policy to ensure the identification, assessment, mitigation and monitoring of risk within our supply chain. This includes a third-party risk appetite statement which formalises the position that Close Brothers has no appetite for third parties taking risks on its behalf that would be unacceptable if taken internally. The Group Third Party Management Policy is further underpinned by standards and procedures which prescribe the risk assessment and due diligence requirements to consistently and effectively identify and mitigate against risks in the supply chain, including consideration of those related to modern slavery.

Sourcing, contractual standards and due diligence

Close Brothers adopts a risk-based approach for selecting and managing its supply chain to ensure that risk is appropriately identified, assessed and mitigated. With a framework underpinned by technology to facilitate the process and drive MI and reporting, the group considers a broad range of risks, including those specifically relating to modern slavery. Our template contractual provisions require suppliers to comply with laws and regulations, including the Modern Slavery Act. These are used wherever possible for new and renewed supplier relationships and include requirements for standards to be passed down the supply chain where appropriate. For suppliers performing more labour-intensive services, such as transportation or manufacturing, enhanced due diligence is performed to identify supplier policies in place to prevent modern slavery, including forced labour, child labour, discrimination and inappropriate labour rights practices.

Actions taken in financial year ended 31 July 2025 

During the financial year ended 31 July 2025, Close Brothers took the following steps with the intention of further ensuring that slavery and human trafficking does not take place in its business or supply chains:

• Continued adherence to the Group Third Party Management Policy and Framework, ensuring our controls remain effective and responsive to emerging risks.
• Maintained integration of Modern Slavery Act requirements into sourcing practices, reinforcing supplier expectations and due diligence.
• Contractual clauses reviewed to allow enforcement of legal standards including modern slavery requirements.
• We have further developed our risk management tooling and complimented this with a new market leading due diligence provider (Helios FSQS) This ensures up-to-date supplier due diligence responses and access to industry best practice through a pooled due diligence approach.
• Maintained continuous third-party monitoring and enhanced this via new partnerships providing sanctions and adverse media intelligence through Dun & Bradstreet and LSEG, delivering real-time alerts and risk insights across our supplier base.
• Refreshed our material supplier risk assessment framework, including modern slavery risk, to ensure our risk profile remains current and that mitigation strategies are targeted and effective.

Next steps

Actions currently planned for the 2026 financial year include:

1. Complete the refresh of risk assessments for all material suppliers, embedding lessons learned and updating controls as necessary.
2. Enhance reporting and KPIs to provide greater transparency to senior management and stakeholders.
3. Further develop continuous monitoring via Dun & Bradstreet, LSEG and our third party management and monitoring partners.
4. Continue to review contractual provisions for adequacy against legal standards including modern slavery.

Approval

This statement is made with respect to the financial year ended 31 July 2025 in accordance with section 54(1) of the Modern Slavery Act 2015. This statement covers Close Brothers Limited, Close Leasing Limited, Close Invoice Finance Limited, Close Brothers Vehicle Hire Limited, and Winterflood Securities Limited (each a “Group Company”) and it has been approved by the Board of Directors of Close Brothers Group plc and each other Group Company.

Close Brothers Group plc and Close Brothers Holdings Limited, the parent entities of the group, did not meet the threshold for inclusion based on their standalone turnover. Close Asset Management Holdings Limited and Close Asset Management Limited are no longer included as they were disposed of in the financial year ended 31 July 2025, and Commercial Acceptances Limited is no longer included as its turnover was below the threshold.

This Statement was approved by the Board of Close Brothers Group plc on 22 January 2026.

Mike Morgan
Chief Executive
Close Brothers Group plc
Date: 22 January 2026