Introduction
In accordance with the requirements of section 54(1) of the Modern Slavery Act 2015 (the Act) this Statement sets out the steps we are taking to prevent modern slavery taking place within our business or supply chain. This Statement was published in May 2023 following approval by the Quilter plc Board1. Previous Statements can be found below.
Quilter plc is a leading wealth management business, helping to create prosperity for the generations of today and tomorrow. The Quilter group of companies2 has an adviser and customer offering spanning financial advice, investment platforms, multi-asset investment solutions and discretionary fund management. Quilter plc oversees £106.7 billion in customer investments (as at 31 December 2023).
Quilter listed on the London and Johannesburg stock exchanges in June 2018 and its financial year end is 31 December. Quilter plc is incorporated in England and it has subsidiaries in various jurisdictions. Details of our subsidiaries and the countries in which they are incorporated, as well as our businesses, are set out in our Annual Report.
Policies
We are committed to conducting business responsibly and upholding the highest standards of governance throughout our operations. Our Group Governance Manual sets out the policies, standards and processes by which the Group operates, and alongside this Statement, sets out the framework that includes our policies relating to, human resources, responsible business, and third-party risk management. We also have codes of conduct for our suppliers and colleagues. You can find out more about a sub-set of these on our website here quilter.com
Our approach to human rights covers not only our supply chains but also our employees and contractors. As such we are committed to paying the national living wage in the UK and expect our suppliers who provide onsite services to do the same. We use both our code of conduct and whistleblowing policy to train and empower our employees to escalate any concerns and ensure they are suitably managed.
Our supply chains
Quilter’s supply chain provides a wide range of products and services. These range from professional advice and business services to more operational services such as cleaning, catering and facilities support. We aim to operate in an ethical manner and we expect the same of our suppliers.
We have aligned and standardised the procurement processes of all Quilter operating companies to our central third-party risk management process. This has enabled us to include modern slavery due diligence uniformly across the Group. Our central supplier management process takes a risk-based approach and includes a risk assessment of new suppliers based on the nature and value of the product or service being procured.
Steps taken to date
We have undertaken several activities over recent years to identify risk in our supply chain, strengthen our response and train and engage our employees. We continued to maintain these practices in the financial year ending 31 December 2022.
Within our third-party management activities, we use a holistic risk assessment to prioritise for review those suppliers which pose a higher risk. This review will include review of contract language and understanding a suppliers’ policies and approach to modern slavery. We also ensure they understand the expectations set out in our Supplier Code of Conduct. For those suppliers identified as high risk, we conduct an annual attestation process which includes consideration of modern slavery.
As well as action with respect to our higher risk suppliers, where appropriate, we ensure our new contracts, and any renewals have suitable wording to address the risk of slavery. Internal processes identify, monitor and address modern slavery and human trafficking risks throughout the procurement and supply chain lifecycle.
Elsewhere in our business, we continued to raise awareness of the risk posed by modern slavery through our Code of Conduct. We also provided dedicated training on modern slavery for our third-party management department, the content of which was fully refreshed in 2022.
Going forward, our on-going priority is to engage with key suppliers to enable collaboration and sharing of best practice on the prevention of modern slavery. We are committed to reviewing and updating our Modern Slavery statement annually.
1This Statement has been approved by the Quilter plc Board of Directors and is made according to the requirements of Section 54 of the Modern Slavery Act 2015 for the financial year ending 31 December 2022. This Statement applies to all companies within the Quilter group that are required to have a modern slavery statement.
2Quilter plc group comprises two segments: ‘Affluent’ and ‘High Net Worth’. The Affluent segment comprises the following operating businesses: Quilter Financial Planning, the Quilter investment platform and Quilter Investors. The High Net Worth segment comprises the following operating businesses: Quilter Cheviot, together with Quilter Cheviot Financial Planning (formerly Quilter Private Client Advisers).