Modern Slavery and Human Trafficking Policy

This statement is made on behalf of Francis Clark LLP (the Firm) and its subsidiary and associated business entities pursuant to section 54 of the Modern Slavery Act 2015 (the Act) and outlines our position on modern slavery and human trafficking. This statement relates to the firm’s financial year ending 31 March 2022 and will be updated annually following each year end.

OUR STRUCTURE AND SUPPLY CHAINS

Francis Clark LLP is a leading independent firm of chartered accountants and business advisers, operating from 8 offices based in the South and South West of the UK. The firm is led by over 50 partners and employs over 700 staff. The vast majority of our staff work in the UK but recently we have engaged 2 employees, through our international network PKF in India. The firm also trades as PKF Francis Clark and is part of the PKF international network of independent firms, which operates across more than 150 countries. The firm has a number of subsidiary companies including PWPS which are covered by this statement. The firm has over 500 direct suppliers, the vast majority of which are in the UK, providing goods and services across a wide range of sectors including IT, marketing, office supplies, facilities management and travel.

OUR COMMITMENT

Modern slavery is an international crime, and a violation of fundamental human rights. The firm adopts a zero tolerance approach towards such crimes, and is working towards implementing systems and practices to ensure that any such breaches within the firm or its supply chains can be identified and dealt with appropriately. Our partners take responsibility for implementing this policy statement and its objectives, and will provide training and adequate communication throughout the firm to ensure that slavery and human trafficking is not taking place within the Firm or its supply chains. We are committed to building our business around strong ethical values. We take appropriate steps to identify, prevent and end all forms of modern slavery and trafficking in our business and its external supply chains.
All staff and partners are in the process of completing a webinar on modern slavery, including an exam which has to be passed. This ensures that all staff are made aware of this crime and trained accordingly to help us spot when our clients, suppliers or other contacts maybe engaging in such practices.

ACTIONS TO MITIGATE RISK

Employment

We apply high standards in the recruitment, selection and employment of our people to ensure that:

• All legal obligations are complied with in the recruitment and induction process;
• We recruit, promote and develop our people on the grounds of merit and capability;
• We pay at least national minimum wage plus 5% for all of our entry level roles;
• We periodically conduct an anonymous and confidential staff survey, in which we elicit views about pay, benefits, working hours and conditions as well as leadership, values and culture;
• We encourage the reporting of concerns and provide appropriate protection for whistle blowers;
• All staff and partners are expected to comply with our business principles, ethical values and our sustainable procurement policy as well as any relevant laws and professional codes of conduct applicable to us;
• We will train new and existing employees to help them understand the issue of modern slavery, and its impact.

Supply Chain

As part of our approach to supply chain management we currently, and will continue to:-

• Build long term relationships with all key suppliers and clearly highlight to them our expectations of business appropriate behaviour and the requirement to meet or exceed all requirements of the Act;
• Undertake reviews of our current suppliers to identify those where the risk may be enhanced either by the nature of the sector or territory where they operate;
• Work with such suppliers to understand their own policies on modern slavery, and terminate relationships with any supplier where breaches of the Act are discovered;
• Develop our standard terms and conditions for suppliers to include a reference to compliance with the modern Slavery Act, and an obligation on suppliers to sign up to our Statement of Supplier Undertakings Relating to Anti-slavery and Human Trafficking Laws;
• When contracting with third-party supplier terms, seek to include contract clauses relating to modern slavery and human trafficking, and where possible, require suppliers to sign up to our Statement of Supplier Undertakings Relating to Anti-slavery and Human Trafficking Laws.