Close Brothers Group anti-slavery and human trafficking statement for the financial year ended 31 July 2017

Group overview

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, with a limited supply chain which predominantly focusses on procuring professional and technology services, with most of its suppliers based in the UK and the 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 and human trafficking. 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 and identify and manage any incidents which do arise. 

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 2017

During the financial year ended 31 July 2017, 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
    Following the publication of the Group Modern Slavery Policy during the 2016 financial year, the policy was further embedded within our business units. The policy applies to all Group companies, divisions and subsidiary businesses, and their respective permanent and fixed-term employees, temporary staff and contractors.
  2. Sourcing Practices
    Close Brothers has considered the requirements of the Modern Slavery Act when sourcing new goods and services from the third party supply market.
  3. Standard Contractual Documentation
    New updated contractual provisions requiring suppliers to comply with the Modern Slavery Act have been used for relevant new and renewed supplier relationships.
  4. Enhancement of Third Party Risk Framework
    Close Brothers invested significant resource to upgrade the Banking division’s Third Party Management framework. As described below, the framework will be further embedded during the 2018 financial year. It 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 enhanced framework includes more detailed and standardised risk assessment and due diligence processes to identify and mitigate against risks, including those of modern slavery in the supply chain. A new target operating model was also developed and approved during the year, which will underpin an expansion and upskilling of the Third Party Management team and the introduction of a Third Party Assurance function, which are considered to be vital in the objective and comprehensive management of critical third party risks.

Next Steps

The newly developed Third Party Management framework and target operating model will be further embedded during the 2018 financial year, and will further enhance the transparency of supply chains in the Banking division, and enable a more effective risk-based approach to third party management. This development will ensure that Close Brothers is better able to identify and then effectively mitigate the risks of modern slavery across its supplier landscape.

Close Brothers’ Banking Division will introduce a Third Party Assurance function in FY18 which will seek to identify critical providers of goods and services and introduce controls and mechanisms to ensure that those providers are acting legally and responsibly, including from a modern slavery perspective.

There will be a focus on ensuring the entire Third Party Management team is trained to the CIPS Ethical Procurement and Supply standard. This is designed to help procurement and supply chain professionals all over the world demonstrate their absolute commitment to, and understanding of, acting ethically on behalf of their organisations. This training will then be repeated on an annual basis to ensure all team members continue to be up to date with CIPS best practices.

Equivalent Third Party Management practices will also be developed in the Securities and Asset Management divisions of Close Brothers to deliver continued improvement in the Group’s ability to ensure modern slavery does not exist within its supply chains.

Approval

This statement is made with respect to the financial year ended 31 July 2017 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, Close Invoice Finance Limited, Close Leasing Limited, Close Brothers Vehicle Hire Limited, Commercial Acceptances 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.

Preben Prebensen
Group Chief Executive, Close Brothers Group plc
31 January 2018