Our approach to climate and nature
Read our climate report in the Shawbrook Annual Report and Accounts.
Supporting the climate transition
Reducing our environmental impact
Embedding environmental considerations in our corporate DNA
Our approach to responsible business practices
Leadership
Our governance framework is designed to provide clear direction, strong oversight, and well-defined responsibilities across the organisation.
Our Board
Our Board is collectively responsible for the effective oversight of our business.
Our Board believes that a range of backgrounds and perspectives enhances Board effectiveness. Therefore, all appointments aim to broaden the Board's composition without compromising the quality of the Board.
Our Executive Committee
The Group is led by an established and stable Executive Committee with significant expertise in specialist lending, financial markets, technology, and risk management.
The Executive Committee is responsible for developing and effectively implementing the Group’s strategy and delivering on our purpose by embedding a culture that empowers our people to be personal, practical, and creative.
Sustainability Principles
We recognise the environmental and social impacts of our customers’ activities and incorporate sustainability considerations into our financing decisions. Our credit policy is guided by sustainability principles that align lending with our broader sustainability strategy.
We identify certain sectors as ‘sensitive’ where activities have the potential to cause negative environmental and/or social impacts. These broadly include carbon intensive sectors such as energy, extractives and heavy industry, emission intensive manufacturing, transport and agriculture as well as selected sectors with elevated social and/or ethical risk exposure, such as gambling, defence and tobacco. For financing within these sensitive sectors, we have exclusions for specific activities and enhanced due diligence (EDD) requirements for transactions not captured by our exclusion criteria. EDD helps to ensure we understand our customers’ plans to reduce or eliminate their negative environmental and/or social impacts. EDD supports informed decision making and helps to mitigate potential credit and reputational risks.
The Sustainability Panel, comprising the Chief Executive Officer, Chief Risk Officer, and Chief Financial Officer, serves as an escalation and decision-making forum for transactions with potentially heightened environmental and/or social impacts.
Sustainable Finance Framework
We are committed to transparently defining and delivering lending with positive environmental and/ or social impact. Our Framework outlines eligibility criteria for such lending and is guided by industry standards such as the EU Taxonomy and International Capital Market Association and Loan Markets Association Green and Social Principles.
Overview of our Sustainable Finance Framework eligibility criteria
Environmental
- Green built environment covers EPC A and B rated properties, other specific industry ratings such as BREEAM and retrofits for existing buildings.
- Energy efficiency covers any assets or activities that result in a minimum 20% energy efficiency improvement or heat loss reduction.
- Renewable and low carbon energy covers assets and activities that relate to these energy sources including wind, solar and biofuels.
- Sustainable infrastructure and transport covers electric, hybrid or alternatively-fuelled transportation and associated infrastructure and activities, with specific emission thresholds.
- Sustainable management of natural resources covers activities that support agriculture, fisheries and forestry, complying with specific sustainability standards.
- Sustainable waste and water management covers activities that provide access to clean water or improves water efficiency and quality.
Social
- Home ownership for specific underserved population including first time buyers, later life borrowers (aged 55 years or above) with assessed incomes below the UK median household income and complex incomes.
- Affordable housing covers social and affordable housing including registered social landlords, and mortgages to government or industry backed schemes such as shared ownership or deposit unlock scheme.
- Healthcare covers all NHS or affiliated with NHS trust, not-for-profit care homes and community health providers.
- Education and training covers all activities not considered private education including not-for-profit schools and schemes for reskilling or upskilling.
- Access to credit and financing covers financing to Community Development Finance Institutions and SMEs that meet specific criteria.
- Access to transportation and infrastructure & access to public spaces covers activities in underdeveloped rural areas or regions in the UK.
Human rights and modern slavery
We are committed to respecting human rights and have a zero-tolerance approach to any modern slavery. We regularly review our process and policies to ensure that any occurrences are addressed swiftly.
Supplier Code of Conduct
We work with suppliers who share our commitment to integrity, accountability and responsible business practices and meet the standards we set.
Shawbrook Group’s Tax Strategy
From a tax perspective, the operation of our business is focused on maintaining the Group’s reputation as a fair contributor to the UK economy, which applies tax law in good faith, and in the spirit in which it is intended.
Managing Tax Risk and Governance
Shawbrook has adopted, and complies with, HMRC’s Code of Practice on Taxation for Banks (the ‘Code’). In line with the Code, we have documented our strategy and governance process for tax matters within our tax policy (the ‘Policy’). The Policy is overseen by the Board, which has delegated this to the Board Audit Committee. The Chief Financial Officer (CFO) has primary responsibility for the Policy, and all other taxation related matters, and is assisted by the Head of Tax.
Given the financial sector in which we operate, the nature and scale of our business, and the volume and complexity of the tax legislation, tax risks arise. The tax risk appetite statement from the Policy seeks ‘to ensure the Group operates with low tolerance for tax risk exposures, and it ensures that full compliance with the spirit (and letter) of all relevant legal requirements, by ensuring staff are properly trained, procedures are documented, and supervisory controls are in place, to ensure that the controls continue to operate effectively’.
Shawbrook Group (“the Group”) has a zero-tolerance approach to Money Laundering & Terrorist Financing (ML&TF). We recognise the harm that financial crime including money laundering, terrorist financing, internal and external fraud, sanctions contravention, bribery and corruption and tax evasion has on our customers, the communities we serve and wider society. The Group has implemented a financial crime framework to detect and prevent financial crime (including tax evasion) and this is monitored using the three lines of defence model of risk management, risk oversight and audit assurance. We continue to enhance the policies, processes and systems used to combat the continuously evolving financial crime threat.
Tax Planning
As required by the Policy, Shawbrook aims to pay the right amount of tax at the right time. The Policy requires that all transactions must have a commercial purpose and that tax evasion or aggressive planning are not acceptable under any circumstance.
We seek external advice in areas of technical uncertainty, either in the application of the legislation or its interpretation. This applies to areas of new and existing business. In relation to any tax planning, the main focus is to ensure that any proposed transaction complies with the letter, and spirit of tax law, and does not provide benefits which cut across the intentions of Parliament.
Relationship with HMRC
Shawbrook seeks to work in partnership with HMRC, by maintaining an open, honest, and constructive relationship in relation to its tax dealings. This enables us to meet the objectives of the Code, and the Policy, and to ensure that we maintain our low-risk tax assessment. When faced with any contentious or uncertain areas, we engage with HMRC on a ‘real-time’ basis, to minimise any potential tax risks, and to provide greater certainty for our tax return filing position.
Our business
Investors
We provide finance to a broad and diverse range of customer segments, each of which value the flexibility, speed and certainty we deliver. Our ambition is to grow our specialist proposition, while retaining our entrepreneurial culture and agility.
About Shawbrook
Shawbrook provides finance to a wide range of customers who value the premium experience, flexibility and certainty we deliver. We are a purpose-led organisation, with a focus on delivering long-term sustainable value for all our stakeholders.
Sustainability
Our sustainability strategy is designed to create value for our customers, colleagues, communities, suppliers and shareholders, while having a positive impact on society and the wider environment.