This statement comprises the Slavery and Human Trafficking statement of Shawbrook Group plc and its wholly owned subsidiary Shawbrook Bank Limited (together ‘Shawbrook’ and the ‘Group’) pursuant to section 54(1) of the Modern Slavery Act 2015 (‘MSA’) for the financial year ending 31 December 2020.
Shawbrook is a specialist UK savings and lending bank founded in 2011 to serve the needs of SMEs and individuals in the UK with a range of lending and savings products. We are a growing UK specialist bank that challenges the conventional approach of the mainstream banks, with our thoughtful and good-sense approach to the way we do business.
Given the nature of the Group’s operations, Shawbrook is at very low risk of exposure to Slavery and Human Trafficking issues. However, the Group continues to take its responsibilities seriously and has sought ways to champion better work and working lives to raise awareness of the issues of Modern Slavery and Human Trafficking.
Shawbrook does not act as a producer, manufacturer, or retailer of any physical goods and, as a financial services provider, it has a relatively straightforward supply chain compared to other sectors. It is not authorised to conduct any financial services outside of the UK; however, some supply chains can be complex in nature and therefore some outsourcing activity takes place outside of the UK.
We strive to achieve mutually advantageous supplier relationships, built on common values and expectations. It is our commitment to conduct business in a responsible and sustainable manner that underpins our engagement with third party suppliers, only working with those that resonate with our core values.
In order to take a proactive stance against Modern Slavery, Shawbrook asks that all of its staff and suppliers, such as cleaning contractors, recruitment consultants, stationery providers, design agencies and catering contractors, are expected to behave, and to be seen to behave, ethically at all times during the sourcing and supply of goods and services for the Group. Shawbrook regularly reviews the contractual terms in place with its preferred suppliers to ensure that they remain pertinent and proactive. These records are reported to and monitored on a regular basis by the Procurement team.
Additionally, all of the Procurement team and Relationship Owners are asked to always comply with the Chartered Institute of Purchasing & Supply’s Code of Professional Ethics.
Shawbrook continues to comply with regulatory requirements on outsourcing, which require us to take all reasonable steps to avoid undue additional operational risk and to take all reasonable steps to ensure that a Service Provider has the ability, capacity and authorisation required by law to perform their outsourced functions, services or activities reliably and professionally.
Shawbrook recognises the role it shares with its suppliers in tackling the growing issues of Modern Slavery. The Group has zero tolerance to Slavery and Human Trafficking and places a duty on all staff to report any potential infringement arising either internally or externally. Detailed background checks are carried out by an independent firm prior to new employees commencing work with Shawbrook, which would capture any criminal records in respect of Slavery and Human Trafficking Offences.
Shawbrook also operates various practices, procedures and policies to ensure compliance with all human rights laws and UK employment laws. Key policies include the:
Appropriate cross-references to Modern Slavery offences have been added to the above policies to further heighten awareness in circumstances where related matters are being addressed.
Throughout the 2020 financial year, the Group has continued to build on the approach introduced over the past few years. During the year an internal Assurance review was conducted on Shawbrook’s compliance with the requirements of the MSA. A small number of improvements were identified relating to staff training and minor amendments to policies, processes and controls, all of which have been completed. We remain concerned and committed to tackling Modern Slavery where we can.
Although Slavery and Human Trafficking concerns are of a low risk to the business, Shawbrook has introduced an approach to ensure ongoing monitoring of suppliers. We assess and review Anti-slavery matters with existing suppliers at the time when each contract is reviewed and/or renewed, and always at inception with any new supplier. We are also part of FSQS (Financial Services Qualification System), which is a community of financial institutions. It is operated by a third party, Hellios, which is recognised for providing total supplier information and risk management solutions and we are confident that this partnership strengthens our ability to systematically monitor supplier activity, ensuring full compliance with our values and relevant legislation, including the MSA.
The Group Procurement and Supplier Performance Management Policy governs the onboarding process and reinforces the importance of due diligence and supplier governance in relation to slavery and human trafficking issues, which as mentioned above requires our colleagues to act ethically and with integrity in all their business relationships.
During 2020, steps were taken to incorporate MSA related clauses in all new contracts with suppliers we identified as being at risk. Contracts with other suppliers will require the supplier to comply with all applicable laws applying from time to time. References to “all applicable laws” would include the Modern Slavery Act 2015.
By having the correct tools (such as the MSA Compliance database and FSQS) and regularly reviewing our policies, we can ensure that any occurrences are swiftly and severely addressed. Should any instances of Modern Slavery be identified, the Group will take internal action and escalate to the relevant authorities, immediately suspending the employee or supplier.
In 2020 there were no reported instances of Modern Slavery within the Group or its Supplier Relationships. The Group will continue to review and monitor its approach to Modern Slavery amongst our colleagues and suppliers on a regular basis.
This statement was approved by the Shawbrook Group Board on 16 March 2021.
Chief Executive Officer
On behalf of:
Shawbrook Group plc and
Shawbrook Bank Limited
16 March 2021