Modern Slavery Act

This statement also covers Shawbrook’s wholly owned subsidiaries The Mortgage Lender Limited (“TML”), Bluestone Mortgages Limited 
(” BML”) and JBR Capital Limited (“JBR”). Although TML, BML and JBR are not individually required to publish a Modern Slavery Statement under the UK Modern Slavery Act 2015, they are included within this statement to demonstrate the Group’s unified and comprehensive approach to identifying, preventing, and mitigating Modern Slavery risks. This reflects our commitment to maintaining consistent governance standards and robust due diligence practices across all Group entities, operations, and supply chains. During 2025 we acquired two further companies – Imployapp Limited, trading as Playter (“Playter”) and ThinCats Group Limited (“Thincats”) and in the course of 2026 we will look to align both those companies to Shawbrook’s Modern Slavery Statement framework.

At Shawbrook, we are committed to preventing modern slavery and human trafficking across our operations, supply chain, and customer relationships. Our approach reflects our core values of integrity, accountability, and respect for human rights, and we maintain a zero-tolerance stance toward all forms of exploitation. We align our controls with UK legislative requirements, regulatory expectations, and relevant international standards, including emerging best practice such as BS 25700.

This statement outlines the steps we have taken during 2025 to identify, assess, prevent, and mitigate modern slavery risks across our operations and business relationships.

About Shawbrook

Shawbrook is a publicly listed UK specialist savings and lending bank serving Small & Medium Enterprises (SMEs), property professionals, retail mortgage customers, and individuals. We provide a broad range of financial solutions supported by strong digital capability and relationship led expertise. Our product suite includes buy-to-let and commercial mortgages, bridging and development finance, SME loans, asset finance, and consumer savings products delivered through the Bank and our specialist subsidiaries.

Our operations and workforce are primarily UK-based, though we engage a limited number of trusted third-party service providers outside the UK. Our supply chain consists of technology and data suppliers, regulated professional-services firms, facilities-management providers, and outsourced operational services.

As a financial-services organisation without manufacturing or retail operations, Shawbrook’s inherent exposure to forced-labour risk is lower than that of sectors where physical goods are manufactured or supplied. However, we recognise that modern slavery risks may arise indirectly through outsourced services, contractors, and complex or international supply chains. Certain service categories, such as technology development, facilities management, and property-related services can present elevated risk, and exploitation within customer sectors may also translate into financial, operational, regulatory, and reputational harm for the Bank if not properly identified and managed.

Our Governance and Commitment

Modern slavery is recognised as a key Financial Crime, Conduct, and Environmental, Social and Governance (ESG) risk and Shawbrook remains focused on mitigating it. The Board Risk Committee provides oversight of Modern Slavery, through our Bank-wide Financial Crime Risk Assessment process, ensuring senior-level visibility and accountability. The Bank-Wide Risk Assessment (BWRA) informs risk appetite, control design, and MI development.

Shawbrook’s management information (MI) framework includes dedicated key risk indicators for modern slavery, supporting earlier identification, escalation, and ongoing monitoring of trends across customers, suppliers, and intermediaries.

In 2025, we further strengthened our MI capabilities, enabling more regular and effective oversight of key risk indicators and emerging trends. This has helped ensure that modern slavery considerations remain embedded within operational processes and decision-making.

Executive responsibility sits with the Money Laundering Reporting Officer, with day-to-day activities jointly delivered by Financial Crime Compliance, Financial Crime Risk Services, Procurement and Supplier Management, People & Culture, Operational Risk and the business units.

Our Policies and Controls

Shawbrook Group maintains a comprehensive policy framework governing human rights, employment standards, and modern slavery. Key policies include:

• Modern Slavery
• Code of Conduct & Ethics
• Third Party Supplier Code of Conduct
• ‘Speak Up’ (Whistleblowing)
• Third-Party Risk Management
• Intermediary Management & Oversight
• Anti-Money Laundering & Counter-Terrorist Financing

Our Modern Slavery Policy serves as the central reference point for roles, responsibilities, and escalation pathways. All policies undergo periodic review to ensure alignment with evolving legislation, regulatory guidance, international standards, and industry best practice.

Embedded due-diligence processes support the identification of modern slavery indicators during the onboarding and management of employees, customers, intermediaries and third parties. These controls operate across the first and second lines of defence to ensure consistency and effectiveness.

Our Supply Chain

Although Shawbrook does not operate manufacturing or retail supply chains, we recognise that modern-slavery risks can arise in outsourced or international service arrangements. We are committed to working with suppliers who uphold strong, ethical labour standards and reflect our organisational values.

Our procurement and Third-Party Supplier Code of Conduct Policies incorporate a dedicated Ethical code of conduct section that sets out our expectations regarding the prevention of modern slavery and human trafficking within our supply chain. We require all suppliers to adhere to these standards, and our contractual arrangements include mandatory clauses addressing modern slavery, human trafficking and all other applicable laws.

For suppliers that are required to cooperate with our due-diligence, audit, and reporting expectations, supplier assessments are conducted during onboarding, contract renewal and in response to risk triggers. No modern-slavery breaches were identified within our supply chain during 2025.

We also comply with UK regulatory outsourcing requirements, ensuring all outsourced service providers have the capacity, capability, and authorisation to deliver services safely and effectively, with appropriate controls in place to prevent modern slavery within their operations and supply chains.

Customer Due Diligence

Modern-slavery risk is embedded within Shawbrook’s wider financial crime framework, ensuring that potential indicators of exploitation are considered at every stage of the customer lifecycle. During onboarding and throughout the ongoing monitoring process, we assess customer ownership and control structures, evaluate business models, review adverse-media results, and apply industry-specific risk scoring to identify vulnerabilities associated with modern slavery or human trafficking. Where higher-risk features are identified, such as complex supply chains, opaque ownership arrangements, use of unregulated labour intermediaries or operations in sectors with historically elevated exploitation risk we undertake enhanced due diligence to develop a deeper understanding of the third parties' practices, controls, and potential exposure.

We pay particular attention to higher-risk sectors within our lending portfolios, including construction, agriculture, logistics, property services, and other labour-intensive industries, where the likelihood of hidden or indirect exploitation is more prevalent. This sector-based approach enables us to proactively identify situations where coercion, unsafe working conditions or unlawful recruitment practices may be present within a customer’s operations or their extended supply chain.

Where concerns arise, whether through due-diligence findings, ongoing monitoring, transactional behaviour, third-party intelligence, or internal staff escalation, they are promptly referred through our established financial crime governance structure. Cases are reviewed by specialists with appropriate expertise, and risk-mitigation actions are taken in line with policy, which may include applying further enhanced due diligence, restricting the relationship, declining applications, or exiting the relationship where risks cannot be adequately mitigated. Confirmed cases of modern slavery result in immediate suspension of the relationship, reporting to relevant authorities, and implementation of remedial actions designed to prevent further harm.

This approach ensures that modern slavery considerations are not treated in isolation but are integrated into decision-making and oversight across the organisation.
 
Through Financial Services Qualification System (FSQS), we receive independent assurance regarding supplier controls and compliance.

Our focus in 2025

During the first half of 2025, Shawbrook maintained its dedicated Modern Slavery Working Group (MSWG), chaired by the Chief Compliance Officer. Set up in 2023, the MSWG brought together senior representatives from Compliance, Risk, Procurement, Operations, HR and key business areas to coordinate activity, oversee progress and drive implementation.

Having made significant progress in 2 years, identifying and drawing together specific modern slavery risks, this standalone forum was retired in the second half of 2025. The responsibilities of the MSWG were then formally integrated into existing risk committees and incorporated into Group risk-appetite reporting, and. Modern-slavery performance indicators and risk metrics are now reviewed monthly through these established governance channels, ensuring continued accountability, meaningful oversight, and sustained enhancement of Shawbrook’s modern-slavery framework.

Throughout 2025, we also progressed a series of improvements to strengthen our response to modern-slavery risk, including:

• Harmonised the existing policies and standards across the Shawbrook Group, including JBR, TML, and BML for Modern Slavery and ‘Speak up.’
• Further enhancements made to contractual protections by embedding modern slavery clauses into lending and supplier agreements.
• Enhanced our ‘Speak Up’ Framework to support confidential and safe reporting of suspected exploitation.
• Embedded modern slavery metrics within our risk appetite, MI, and control testing framework.
• An internal assurance review confirmed our overall modern slavery policy framework and underlying processes are considered effective.
• Continued development of due diligence on customers within higher risk sectors.

Looking ahead

In 2026, we will broaden our supplier risk segmentation, extend thematic risk scanning to a wider range of counterparties, with a strengthened focus on identifying and addressing modern-slavery risks, supported by enhanced end-to-end MI reporting. Following the acquisitions of ThinCats and Playter in 2025, we also plan to align those newly acquired subsidiaries to Shawbrook Group Policies and Standards during 2026, ensuring consistent expectations and a unified approach to modern-slavery risk across the Group.

Measuring Effectiveness

We continue to monitor and assess our modern-slavery controls via key performance and risk indicators, internal audits, supplier assessments, and employee training with supplier assessments undertaken annually. In 2025 there were no confirmed instances of modern slavery or human trafficking within our operations, supply chain, or customer base.

Any modern slavery concerns reported via Shawbrook’s ‘Speak Up’ framework managed by Compliance are escalated to the Financial Crime Compliance Team for assessment and if necessary, investigation. There were no such concerns raised in 2025.

Training and Awareness

All colleagues complete mandatory modern-slavery training at induction and as part of the annual refresher cycle. This training ensures colleagues understand how to identify potential indicators of exploitation and how to escalate concerns appropriately. In 2025, completion rates remained at 100% for all eligible colleagues.

Statement of Approval

This statement was reviewed by Shawbrook’s Executive Committee and then approved by the Board on behalf of Shawbrook Group plc and Shawbrook Bank Limited on 04 March 2026, in accordance with the requirements of the Modern Slavery Act 2015.

Marcelino Castrillo
Chief Executive Officer

On behalf of:
Shawbrook Group plc and 
Shawbrook Bank Limited

04 March 2026