Modern Slavery Act

This statement also covers Shawbrook’s wholly owned subsidiary The Mortgage Lender Limited and Bluestone Mortgages Limited which have fully aligned their policies and procedures around modern slavery to those of the Group. During 2025 we will also be aligning JBR Capital Limited (acquired in 2024) to Shawbrook’s Modern Slavery Statement framework. 

Business Structure

Shawbrook is a specialist bank which exists to serve the needs of real estate professionals, Small Medium Enterprises (SMEs), Commercial and Retail Mortgage customers and consumers in the UK with a range of lending and savings products. 

Given the nature of the Group’s business and operations – both now and looking forward - Shawbrook is at very low risk of direct exposure to slavery and human trafficking issues. However, the Group continues to take its responsibilities seriously and has sought ways to continue to raise awareness of the issues of modern slavery and human trafficking internally. 

Supply Chains and Risk Assessment

As a financial services provider which does not manufacture, produce or sell any physical goods, and has no retail premises, Shawbrook has on the whole 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 professional 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, are expected to behave ethically at all times during the sourcing and supply of goods and services for the Group. 

As part of its procurement process, modern slavery risk is included in the wider financial crime risk assessment which is undertaken when onboarding new suppliers above £5,000.  Shawbrook periodically reviews the due diligence and contractual terms in place with its suppliers to ensure they remain relevant. These supplier records held on our third-party supplier system are monitored on a regular basis by the Procurement team and/or the Relationship Owner and any breaches are reported. There were no reported breaches in 2024.
Additionally, the Procurement team are asked to comply with the Chartered Institute of Purchasing & Supply’s Code of Professional Ethics in relation to procurement activity.

https://www.cips.org/cips-for-business/performance/ethics/corporate-code-of-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 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.

With respect to Shawbrook customers, as part of our customer due diligence standards we look to identify and verify control and ownership structures for all entities and then screen all relevant parties for adverse media. Additionally, as part of our risk assessment process, we have factored in industry risk scores that are inherently higher risk for modern slavery and human trafficking. These customer risk scores then drive additional due diligence requirements and heightened ongoing monitoring.

Policies in relation to Slavery and Human Trafficking

Shawbrook recognises the role it shares with its suppliers in tackling 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 several practices, procedures and policies to ensure compliance with all human rights laws and UK employment laws.

Appropriate cross-references to modern slavery offences have been added to relevant policies to further heighten awareness in circumstances where related matters are being addressed.
Furthermore, modern slavery and human trafficking are addressed within our financial crime framework. Shawbrook monitors its risk exposure to the facilitation of modern slavery and human trafficking through risk assessments, due diligence and ongoing monitoring measures completed on our customers and associated parties such as brokers and intermediaries.

Although modern slavery and human trafficking concerns are of a very low risk to the business, Shawbrook continues to ensure ongoing monitoring of suppliers. We assess and review anti-slavery matters with existing suppliers in scope of the regulations 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 Policy governs the onboarding process and reinforces the importance of due diligence and supplier governance in relation to modern slavery and human trafficking issues.
MSA related clauses are incorporated into all new contracts with suppliers in scope of the regulations whom 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.
As noted above, due diligence is also conducted on customers, brokers and intermediaries that also reflect inherent risks from modern slavery and human trafficking.

By having the correct tools and regularly reviewing our policies, we can proactively assess MSA risk. Should any suspicions of modern slavery be identified, the Group will take internal action and escalate through the relevant governance framework for review. 
If any of these cases are confirmed, relevant authorities are notified and all relevant relationships suspended (i.e. employee, customer, intermediary, or supplier).

2024 Enhancements

2024 Activity Modern Slavery Policy

To supplement the existing policy framework, in 2024 the Group created a specific Modern Slavery Policy. By creating one central policy the Group ensured dedicated focus on this important risk area and increased the effectiveness of its anti-modern slavery controls. 

Modern Slavery Working Group

Shawbrook maintained a Modern Slavery Working Group, chaired by the Chief Compliance Officer throughout 2024. This has group wide representation and ensures that a focus on Modern Slavery risk and the sharing of knowledge is maintained. The terms of reference of this working group, which meets quarterly, state that its purpose is to ensure accountability for compliance with the Group’s modern slavery controls framework and to identify opportunities for further enhancement. 

Commercial

The Group continued to consider the risk of modern slavery in the context of its lending business. All of Commercial's procedures and operational guidance documents including third party external documents were reviewed in 2024 to ensure that Modern Slavery guidance and checks are present. The intranet pages were also updated to provide enhanced details on Modern Slavery.

Whistleblowing (Speak Up) Framework

We encourage a culture of transparency and accountability within our organisation. Employees are encouraged to report any concerns related to modern slavery through our confidential whistleblowing channels. All reports are taken seriously and investigated promptly. Further enhancements will be made to our Whistleblowing Framework in 2025 enabling employees to raise concerns completely anonymously through an independent reporting channel.

Due Diligence Process

To mitigate the risk of modern slavery within our supply chains, we have established rigorous due diligence processes. These include:

1. Supplier Assessments: We conduct thorough assessments of our suppliers above £5,000 to ensure they adhere to our standards and policies on modern slavery.
2. Risk Assessments: Regular risk assessments are conducted to identify and address potential areas of concern within our operations and supply chains.
3. Audits: We perform audit of material suppliers to verify compliance with our modern slavery policies.

Measuring effectiveness

In 2024 there was no reported instances of modern slavery within the Group or its Supplier Relationships. A further assurance review will take place in early 2025 to test for evidence of the extent to which modern slavery risks have been embedded into policies and processes.

The Group will continue to review and monitor its approach to modern slavery amongst our colleagues and suppliers on a regular basis. 

Training and Awareness

We recognise the importance of educating our employees and stakeholders about the risks and indicators of modern slavery. To this end, we have implemented comprehensive training programmes, including mandatory training across all eligible employees. This was further supplemented by and face to face training and awareness sessions for higher risk areas.

Future Steps

We are committed to continuously improving our practices and policies to combat modern slavery and will continue to explore ways to further enhance our controls in 2025.

Board Approvals

This statement was reviewed by the Bank’s Executive Committee and then approved by the Shawbrook Group and Shawbrook Bank Board on 25 March 2025.

Marcelino Castrillo
Chief Executive Officer

On behalf of:
Shawbrook Group plc and 
Shawbrook Bank Limited

25 March 2025