Modern Slavery Statement

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 set out the steps that Brown Shipley has taken to ensure that slavery and human trafficking is not taking place in its supply chain or any parts of its business.
 
 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 December 2023 .

Organisational Structure and Culture
Brown Shipley’s principal activity is to provide wealth management services comprising investment management, wealth planning, lending, and other private banking services to its clients, which mainly consist of private individuals.

The Company’s vision is to be recognised as a trusted partner to its clients and as a leading private bank, providing integrated wealth management solutions to those clients. The Company’s mission is to preserve and grow each client’s wealth across generations.

Brown Shipley has eight offices across the UK and its parent company is Quintet Private Bank (Europe) S.A, head quartered in Luxembourg.,. 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. 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:
  1. Undertaken a review of their supply chain; Established that it is free from modern slavery; and
  2. 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.

As a UK based financial services business,  Brown Shipley believes there is a relatively low risk of modern slavery within its employee base and direct supply chain. The most prominent risk of encountering Modern Slavery lies where Brown Shipley does not have direct management control or direct engagement downstream in its supply chain. This may include suppliers that provide support staff in, for example, cleaning or security activity. Brown Shipley requires suppliers to have policies and procedures in place  to mitigate  this risk.

Training and Policies
Brown Shipley uses its e-learning portal to raise awareness on several issues relevant to the Act.

We have culture training, 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. Concerns can be raised through various channels, including contacting our Head of Compliance, Head of Internal Audit and Head of HR. Our Independent Non-Executive Director, acts as our whistleblowing champion.

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 28   April 2024.