Modern Slavery Statement

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Brown Shipley is committed to addressing the requirements of the UK Modern Slavery Act 2015 (the “Act”). We acknowledge the undertakings in the Act and the risks of modern slavery, and will aim to create a culture of transparency with regards to the supply of goods and services to us.

This statement is made pursuant to section 54 of the Act and constitutes the Company’s modern slavery and human trafficking statement, as required by the Act, for the financial year ended 31 March 2020.

Organisational Structure and Culture

Brown Shipley has eight offices across the UK and its parent company is Quintet Private Bank based in Luxembourg. We believe that the current business practices and corporate structure operate free from risk in relation to modern slavery, however we recognise that there is work to be done to be able to evidence the full requirements of the Act. We are committed to the highest standards of integrity and ethical behaviour and our policies and practices reflect this.

Supply chains and due diligence procedures

We are committed to ensuring that our supply chain is free of any slavery and/or human trafficking. We will not knowingly support and/or do business with any suppliers who are involved in slavery.

Brown Shipley aims to identify and eradicate any slavery risks. In 2019/20 we have:

Adopted a process to request information regarding third party supplier’s working practices and require the relevant key supplier to confirm that it is aware of, and complies with, its obligations under the Act;
Communicated to potential key suppliers that we have a zero tolerance policy with regards to slavery;
Ensured that key suppliers provide confirmation that they have:
- Undertaken a review of their supply chain; Established that it is free from modern slavery; and
- Ensure that all their representatives (including employees, agents, suppliers and subcontractors) conduct business with and/or on behalf of Brown Shipley in accordance with the our procedures.

We recognise our obligations under the Act, and will continue to work towards a full set of procedures to meet the requirements during 2020/21. We will:

Establish due diligence procedures to assess the nature and extent of our exposure to the risk of slavery;
Communicate to suppliers that they are required to undertake continued self-monitoring and promptly inform Brown Shipley of any violations of the Supplier Code of Conduct; and
Include reference to, and compliance with, these slavery supply chain issues in our supplier engagement process, supplier audit procedures and contractual arrangements with third party suppliers.

Training and Policies

We recognise that training is fundamental to raising awareness of modern slavery issues, and will identify relevant online training and appropriate guidance to provide an understanding of slavery.

Such training will be rolled out to key stakeholders who will be made aware of how to identify, manage and report risks.

We already have culture and ethics training and whistleblowing policies in place encouraging employees to behave in a responsible and professional manner and to speak up in instances where this behaviour is not observed.

Monitoring and adherence

The responsibility for adherence to this policy will lie with all employees who interact with the third party suppliers. Employees who are aware of, or suspect, any violation of the Act will be required to report such conduct to HR or Legal. Brown Shipley’s Whistleblowing Policy encourages all employees to raise concerns and/or disclose information without fear of retribution.

Measuring
success

Brown Shipley will continue to develop key performance indicators to measure the effectiveness of its approach to modern slavery which will include:

Effective deployment of training to key stakeholders;
Completion of due diligence procedures undertaken on key suppliers;
Ongoing monitoring of key suppliers; and
Effective procedures for employees and/or suppliers to escalate modern slavery concerns.

Approval

This statement, which will be reviewed annually and updated as required, has been reviewed by key stakeholders and has been approved by the Brown Shipley Board on 02 December 2020.