Modern Slavery and Human Trafficking Statement

Introduction

This statement on Modern Slavery and Human Trafficking pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) is made on behalf of Evelyn Partners Group Limited and its subsidiary companies (the “Group”) for the financial year ended 31 December 2024. 

Scope

The statement is published on behalf of the Group as a whole but in particular on behalf of the following UK entities: 

  • Evelyn Partners Services Limited
  • Evelyn Partners Discretionary Investment Management Limited
  • Evelyn Partners Investment Management Services Limited
  • Evelyn Partners Financial Planning Limited
  • Evelyn Partners LLP
  • Evelyn Partners Fund Solutions Limited
  • Evelyn Partners Investment Management LLP 

Organisation

The Group provides a wide range of services across its subsidiaries and connected companies, providing integrated wealth management and professional services, from financial planning, investment management, online investment services and fund solutions to accountancy, tax, assurance and advisory services. The Group operates under the Evelyn Partners brand and the Bestinvest sub-brand, a dedicated online investment management platform, from offices in the UK, Ireland and the Channel Islands. 

Supply Chain

Our supply chain is predominately based in locations where our offices are, being the UK, Ireland and Jersey. We do have services provided by suppliers globally, including but not limited to, India, US and Switzerland. Due to the nature of our operations, we have assessed that the Group is at low risk of slavery or human trafficking in our business and supply chain. Our supplier and outsourcing arrangements include information technology service providers, facilities management or other providers who are themselves regulated entities, for example legal or audit services. However, we have taken steps to protect against modern slavery risks by requesting evidence from suppliers of their modern slavery policy, during the tender process. We also ask new suppliers to abide by our Supplier Code of Conduct. 

Our procurement policy has modern slavery assessments integrated into our procedures. During the tender process we require confirmation that the supplier complies with the Act and request evidential proof of their policy or statement. In 2023, we requested completion of an Environmental, Social and Governance (ESG) questionnaire, covering several ESG themes, including Modern Slavery, requiring selected suppliers, including Tier 1, Tier 2 and selected Tier 3 suppliers, to confirm they have a Modern Slavery policy and whistleblowing procedures. Our due diligence process additionally requires verification that they have policies for their workers and contractors regarding fair treatment and pay of workers and contractors, adequate whistleblowing procedures and that those employed in the provision of services have the necessary documentation to legally work in the UK. 

Annual due diligence takes place for our material outsourcing arrangements, and this requires confirmations that suppliers have taken steps to ensure that their supply chain is free from any modern slavery. 

ESG considerations – Responsible Investment

Responsible investment involves considering material environmental, social and governance (ESG) issues when making investment decisions, known as ESG integration, and influencing companies or assets, known as active ownership or stewardship. At Evelyn Partners, responsible investing is the default approach across all our investment services and products. There is a combined focus on the analysis of traditional financial risks alongside significant ESG factors, together with an active stewardship programme.

We believe responsible investment strengthens our internal processes. We also believe this is at the forefront of our fiduciary duty to our clients. We are signatories of the UK Stewardship Code and the UN Principles of Responsible Investment.

Non-financial factors can have a significant impact on long-term financial performance and risk profile of investments, both positively and negatively. We note that companies with high standards of governance and corporate behaviours are likely to have more resilient business models. When investing in third-party funds, we work to choose those with a similar commitment to ESG integration and stewardship as Evelyn Partners.

We aim to be active stewards of the businesses in which we invest where necessary. We use our influence to improve ESG practices and performance in investee companies and with collective investment managers. We do this by engaging (directly and collaboratively) where we have material shareholdings and by voting at shareholder meetings. As stewards of our clients' capital, we seek to encourage better business practices, which should both enhance the value and reduce potential risks. 

Addressing modern slavery in our investments

We are dedicated to ensuring that modern slavery and human trafficking do not occur within any part of our supply chain or business. While we cannot guarantee that our entire investments are free from slavery, we are committed to continuously promoting best practices in the companies in which we invest.

We have been identifying and monitoring a number of indicators such as Supply-chain labour standards or Operations and suppliers at significant risk of incidents of child labour or of compulsory labour through a number of internal processes for several years. We ensure that outliers are escalated to the relevant investment groups who can then decide on relevant actions to be taken, for a full list of indicators and factors identified, please refer to the Sustainability-Related Disclosures on our website.

One of the key means at our disposal for managing and mitigating modern slavery risks is through engagement, often in collaboration with other investors. Other relevant actions could also include deep dives into stocks, dropping coverage, querying the accuracy of data, or escalating to our data providers.

The Group is a member of the collaborative engagement platform Find It, Fix It, Prevent It, an investor-led multi stakeholder project aiming to increase the effectiveness of corporate efforts against modern slavery. Originally set up to focus on the hospitality industry, this has been extended to the construction industry as another sector identified as vulnerable to this risk. We are involved in engagements with three companies where we have shareholdings to help them develop and implement better processes to reduce this risk.

The Group also actively participates in working groups for industry wide initiatives and is a member of the following entities: 

  • The Investment Association
  • Personal Investment Management and Financial Advice Association (PIMFA)
  • The Investing and Saving Alliance (TISA)

These bodies support their members in developing best practice approaches to industry wide problems and help inform our strategy and policies.

Monitoring and training

As mentioned above, annual due diligence takes place for our material outsourcing arrangements.

Modern slavery training is available to all colleagues via our e-learning site. This online module provides the knowledge on how to report, acknowledge and handle modern slavery in the workplace and our supply chain.

Our Whistleblowing Policy encourages and enables staff to raise any concerns, confidentially. Contractors working on our premises also have the right to protection under this policy.

This statement has been approved by the Board.

For and behalf of the Board:

Paul Geddes

Chief Executive Office

Date: 15 March 2025