SHAWBROOK GROUP PLC modern slavery statement summary (2023)

Organisation address
Floor 10, 40 Leadenhall Street,
London,
EC3A 2BJ

We asked the organisation a series of questions about its modern slavery statement. Its answers are published on this page as a statement summary.

This statement provides information for all 6 recommended topics

What is a modern slavery statement?
UK law requires certain organisations to publish an annual modern slavery statement on their website, setting out the steps they are taking to address modern slavery risks in their operations and supply chains. Read more in the government guidance on publishing modern slavery statements.
Link to full statement
Go to full modern slavery statement on organisation’s website

PDF version of the statement

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Modern Slavery Act Statement March 2022.pdf

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About this statement summary

All answers relate to the financial year covered by the statement. The organisation is responsible for all the information it provided. Some of our questions are optional, so organisations may not have answered all of them. The statement summary does not replace the full modern slavery statement – below we provide a link to the full statement on the organisation’s website.

Contents

Organisations covered by the statement

SHAWBROOK GROUP PLC modern slavery statement for 2023 is a group statement covering 2 organisations. See the full list of organisations covered by this statement

Statement period and sign-off details

The statement covers the following period:
1 January 2022 to 31 December 2022

The statement was signed off by:
Marcelino Castrillo (Chief Executive Officer)

It was approved by the board (or equivalent management body) on:
29 March 2023

Recommended topics covered by the statement

Government guidance encourages organisations to cover a range of topics in their modern slavery statements, setting out the steps they’re taking to address modern slavery risks in their operations and supply chains. Read about the recommended topics in the statutory guidance.

We asked the organisation to tell us which topics its statement covers.

Topics recommended by government guidance Organisation’s response
The organisation’s structure, business and supply chains Covered
Policies Covered
Risk assessment Covered
Due diligence (steps to address risk) Covered
Training about modern slavery Covered
Goals and key performance indicators (KPIs) to measure the effectiveness of the organisation's actions and progress over time Covered

The organisation’s sectors and turnover

Sectors

The organisation operates in the following sectors:

  • Financial, insurance and real estate activities

Turnover

Its turnover in the financial accounting year of this statement was:

£36 million to £60 million

If the organisation is a public body, this amount is based on the organisation’s budget for the year of the statement.
What does 'turnover' refer to in group statements?
If this is a group statement, this includes the total turnover for all the organisations covered by the statement.

Number of years producing statements

The organisation has been producing modern slavery statements for the following number of years:
1 to 5 years
How does this work for group statements?
If the statement is for a group of organisations, this answer applies to the organisation with the longest history of producing statements.

Policies (optional)

We asked the organisation whether its policies include the following provisions in relation to its domestic and international supply chains, as well as its own operations.
Policy provisions we asked about Organisation’s response
Freedom of workers to terminate employment Included
Freedom of movement Included
Freedom of association Not included
Prohibits any threat of violence, harassment and intimidation Included
Prohibits the use of worker-paid recruitment fees Included
Prohibits compulsory overtime Included
Prohibits child labour Included
Prohibits discrimination Included
Prohibits confiscation of workers' original identification documents Included
Provides access to remedy, compensation and justice for victims of modern slavery Not included
Other
Not included

Training (optional)

We asked the organisation whether it provided training on modern slavery, and who it was for.
What counts as training?
We explained that by ‘training’ we meant anything designed to increase knowledge and skills around identifying, addressing or preventing modern slavery risks. This could range from formal training courses to broader awareness-raising activities such as workshops or webinars.
We asked who the training was for Organisation’s response
Your whole organisation No
Your front line staff No
Human resources No
Executive-level staff No
Procurement staff No
Your suppliers No
The wider community No
Other
All employees receive Modern Slavery Training

Monitoring working conditions (optional)

Engaging with others

We asked the organisation to tell us who it engaged with to help monitor working conditions across its operations and supply chains.
We asked who the organisation engaged with Organisation’s response
Your suppliers Yes
Trade unions or worker representative groups No
Civil society organisations No
Professional auditors No
Workers within your organisation Yes
Workers within your supply chain No
Central or local government No
Law enforcement, such as police, GLAA and other local labour market inspectorates No
Businesses in your industry or sector Yes

Social audits

We asked the organisation to tell us about any social audits it used to look for signs of modern slavery.
What are social audits?
A social audit is a review of an organisation’s working practices from the point of view of social responsibility, and should include an evaluation of working conditions in the organisation’s operations and supply chains. By their nature, audits of supplier workplaces represent a snapshot in time.
Social audits we asked about Organisation’s response
Audit conducted by your staff Yes
Third party audit arranged by your organisation No
Audit conducted by your supplier’s staff No
Third party audit arranged by your supplier No
Announced audit No
Unannounced audit No

Grievance mechanisms

We asked the organisation how workers in its operations or supply chains could raise concerns or make complaints.
We asked if workers could raise concerns this way Organisation’s response
Using anonymous whistleblowing services, such as a helpline or mobile phone app Yes
Through trade unions or other worker representative groups No

Other ways of monitoring working conditions

We asked the organisation whether it had any other ways of monitoring working conditions across its operations and supply chains:
Shawbrook carries out due diligence of suppliers. Anti-slavery matters are assessed with suppliers at onboarding and during the relationship.

Modern slavery risks (optional)

Warning Identifying modern slavery risks is a vital step towards eradicating it. The government encourages organisations to be as open and transparent as possible, to improve understanding, collaboration and best practice around tackling this worldwide problem.
We asked the organisation to describe up to 3 priority risks it focused on during the period of the statement, including details of the affected workers, the activity involved, and the location.

Priority risks for this organisation (1 of 3)

Supply Chain Risk - Forced labour within the supply chain could pose a risk to Shawbrook
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Within your supply chains.
  • Tier 2 suppliers
    Provide products and services to your organisation via your Tier 1 suppliers.
  • Tier 3 suppliers and below
    Provide products and services to your organisation via your Tier 2 suppliers or the next higher level in the chain.
Who was it most likely to affect Organisation’s response:
  • Women
  • Migrants
  • Refugees
  • Children
  • Possible Labour Exploitation within Supply Chains
In which country Organisation’s response:
  • United Kingdom
  • India
Actions or plans to address this risk Organisation’s response: Shawbrook ensures onboarding assessment of suppliers. Anti-slavery matters with existing suppliers are assessed at the time of the initial contract and when each contract is renewed. Contract Clauses for MS have been added for suppliers, In addition training has been provided to all employees raising awareness.

Priority risks for this organisation (2 of 3)

Customers/Brokers/Intermediaries - The risk of facilitating businesses that are involved in Modern Day Slavery.
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Organisation selected ‘Other’ and wrote:
Possible Labour Exploitation within businesses we support
Who was it most likely to affect Organisation’s response:
  • Women
  • Migrants
  • Refugees
  • Possible Labour Exploitation within businesses we support
In which country Organisation’s response: United Kingdom
Actions or plans to address this risk Organisation’s response: Shawbrook has strengthened its CDD processes to enhance the control framework on MS and has strengthened its lending terms and conditions with trading businesses to include confirmation of compliance with anti-modern slavery and human trafficking legislation. Training and awareness has been provided to all employees on how to spot the signs. Use of Industry codes and country ratings are factored into risk assessment for sectors & countries higher risk of MS. MS statement checks are in place.

Priority risks for this organisation (3 of 3)

Employees - The risk of unknowingly employing individuals who are enslaved/forced to work for little or no pay.
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Within your own operations.
Who was it most likely to affect Organisation’s response:
  • Women
  • Migrants
  • Refugees
In which country Organisation’s response: United Kingdom
Actions or plans to address this risk Organisation’s response: Shawbrook operates practices, procedures and policies to ensure compliance with all human rights laws and UK employment laws. Cross-references to MS offences have been added to policies, with employee training to raise awareness for MS. Employee checks are conducted at commencement of employment. A whistleblowing policy is in place and an anonymous mechanism for reporting is available.

Indicators of forced labour (optional)

We asked the organisation whether its statement refers to finding any International Labour Organization (ILO) indicators of forced labour.
What are ILO indicators of forced labour?
The International Labour Organization (ILO) has produced a list of the most common signs of forced labour. They’re based on the definition of forced labour as ‘all work or service which is extracted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.’ More details and guidance are available on the ILO website, and in their publication ILO indicators of forced labour
Organisation’s response
The organisation told us its statement does not refer to finding any International Labour Organization (ILO) indicators of forced labour.

Demonstrating progress (optional)

We asked the organisation how its statement demonstrates progress over time in addressing modern slavery risks. They provided the following answer:
Induction and annual Mandatory Training for MS was recorded at 100% completion rate with no reports of MS instances throughout 2022. An assurance review carried out identified areas that required enhancing around embedding MS into Shawbrook's Policies and Procedures. Regular monitoring and enhancements are planned for 2023.