Modern Slavery and Human Trafficking Policy

8th October, 2018

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 2017, 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 59 partners and employs around 650 staff, again all within the UK. 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 and Francis Clark Tax Consultancy Ltd, all of which are covered by this statement. The firm has over 5,000 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.

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 develop employee training to help our staff understand the issue of modern slavery, and its impact.

SUPPLY CHAIN

We endeavor to build long term relationships with all key suppliers and clearly highlight to them our expectations of business appropriate behavior and the requirement to meet or exceed all requirements of the Act. We will not support or deal with any business knowingly involved in slavery or human trafficking. In the current year we are undertaking an analysis 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. We will work with such suppliers to understand their own policies on modern slavery, and would terminate the agreement with any supplier where breaches of the Act are discovered.

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