Modern slavery and human trafficking


This statement is made in accordance with section 54(1) of the Modern Slavery Act 2017 and constitutes RBC Brewin Dolphin’s modern slavery and human trafficking statement for the financial year ending 30th September 2022. Approved by the Board on 21 March 2023.

Brewin Dolphin Holdings Limited and its subsidiaries (“RBC Brewin Dolphin”, “we”, “us” or “our”) are responsible employers and seek to ensure that the behaviours and practices of our supply chain reflect our own business standards and compliance with applicable laws and standards. We take a zero tolerance stance on slavery and human trafficking within our workforce and expect the same from our supply chain.

Organisation structure and business of RBC Brewin Dolphin:

RBC Brewin Dolphin is a leading, UK wealth manager with its head office located in London. RBC Brewin Dolphin is a wholly-owned subsidiary of Royal Bank of Canada with full investment autonomy and substantial operational independence.

Brewin Dolphin Holdings Limited is the holding Company for two wholly owned and regulated trading companies, Brewin Dolphin Limited (for the UK and Jersey) and Brewin Dolphin Wealth Management Limited (for the Republic of Ireland).

Supply Chains:

RBC Brewin Dolphin does not act as a producer, manufacturer or retailer of any physical goods. As a provider of financial services, we do not have a very long or complex supply chain – our main vendors are providers of office supplies and support services such as reprographics, IT, recruitment, legal, accountancy, marketing, public relations and facilities management. While we consider our vendors to be at relatively low risk of engaging in practices of modern slavery and human trafficking, we nevertheless remain committed to preventing the occurrence of any such practices both in our business and our supply chain.

Policies in relation to Slavery and Human Trafficking:

As part of our commitment to combatting modern slavery, we have a Modern Slavery Policy which reflects our commitment to acting ethically and with integrity in all our business relationships, which includes all third party relationships as governed by the Vendor Management Policy.

Due diligence processes:

In order to mitigate the risk of modern slavery and human trafficking in our supply chain, all new RBC Brewin Dolphin vendors that meet certain thresholds are required to complete a due diligence questionnaire before they engage with us. This questionnaire includes a requirement for vendors to confirm that they are not contravening slavery or human trafficking legislation. If a vendor is unable to provide such confirmation, RBC Brewin Dolphin adopts a zero tolerance approach and would not engage that vendor.

Real Living Wage

In addition, RBC Brewin Dolphin is also an accredited Living Wage Employer, which means that it is incumbent upon us to ensure that all applicable vendors (as defined by the Living Wage Foundation) pay their staff the Real Living Wage.

Training:

In the last year, RBC Brewin Dolphin has provided training to staff in roles considered to be at greater risk of exposure to incidences of modern slavery and human trafficking. The training educated relevant staff members on the offences of modern slavery and human trafficking, as well as the signs to look for to identify potential victims. The training is targeted at a level which is suitable and reflective of the level of risk we face in this area. In addition, all staff members were provided a high level overview of the risks of modern slavery in their annual conduct risk training.

Our effectiveness in combating slavery and human trafficking:

RBC Brewin Dolphin has a whistleblowing procedure in place (our “Speak Up” policy), which includes mandatory training for staff members, and also conducts annual staff engagement surveys, both of which are opportunities for staff members to raise their concerns regarding slavery or forced labour. The Speak Up policy allows for issues of concern to be escalated to members of the Board of Directors (“Board”) as well as the executive management team so that they can be dealt with properly.  In addition, RBC Brewin Dolphin has a Speak Up statement on our website in the Links section. This Speak Up statement sets out the process external parties (such as suppliers, clients or other third parties) can use to raise concerns.

We continue to develop our approach to combating modern slavery and human trafficking during the course of 2023. In the interim, we will continue to assess and manage risks on an on-going basis. Our aim is to apply the same ethical standards to our staff members and our vendors with transparency and accountability.

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2017 and constitutes RBC Brewin Dolphin’s modern slavery and human trafficking statement for the financial year ending 30th September 2022.

Robin Beer, Chief Executive Officer
This statement was approved by the Board on 21 March 2023.


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