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 2025. 

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 Investment Management LLP
  • Evelyn Partners Investment Services Limited

Organisation

The Group provides a wide range of services across its subsidiaries and connected companies, providing integrated wealth management services, from financial planning, investment management, online investment services 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 also have global service providers, 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. We also request completion of an Environmental, Social and Governance (ESG) questionnaire, covering several ESG themes, including Modern Slavery, of selected suppliers including all our significant suppliers, including Tier 1, Tier 2 and selected Tier 3 suppliers, to confirm they have a Modern Slavery policy and whistleblowing procedures and request evidence of both. 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. Our engagement and voting activities are designed to influence positive change where standards fall short of our expectations, with the aim of improving the long-term value of our clients’ investments. We engage directly with companies and funds, and collaboratively with other investors, to address key risks identified by our responsible investment priorities.

We are signatories of the UK Stewardship Code and the UN Principles of Responsible Investment. For more information on our approach to responsible investing and stewardship, please see our website.

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 investments are free from slavery risks, we are committed to continuously promoting best practices in the companies in which we invest.

We identify and monitor indicators such as supply-chain labour standards,  operations and suppliers with significant risk of child labour / compulsory labour incidents or any companies with alleged violations of the United Nations Global Compact principles. Potential actions include querying the accuracy of data with our data providers, engagement and dropping coverage. For an illustrative list of indicators and factors identified in our screening process, 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. 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 in sectors identified with vulnerability to this risk. We provide regular reports on our collaborations and engagement activities in our stewardship reports.

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

  • 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 responsible investment, including addressing industry wide problems and sustainability risks.

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. We developed a mandatory stand-alone learning module for colleagues in our Finance, Risk & Compliance, General Counsel Office, Financial Crime and Human Resources business areas, with a completion rate of 100%.

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. A mandatory whistleblowing learning module has been rolled out to all colleagues via our e-learning site.

This statement has been approved by the Board.


For and behalf of the Board:

Paul Geddes

Chief Executive Officer

Date: 5 March 2026