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 (the Group) 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 2023 and will be updated annually following each year end.

Our structure and supply chains

The Group is a leading independent firm of chartered accountants, business advisers and Financial Planners operating from 9 offices based in the South and Southwest of the UK. The group is led by over 50 Partners and employs over 900 staff within the UK. The LLP 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 Group has several subsidiary companies including Francis Clark Financial Planning LTD, FC Payroll Solutions and Francis Clark Tax Consultancy Ltd, all of 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 recruitment, 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 continues to develop and enhance 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 continue to provide training and adequate communication throughout the Group 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.

Risk assessment

The Board undertakes a recurring risk assessment to identify the parts of its business and supply chain where there is a risk of human trafficking taking place. The results of this assessment for the current year have identified the current areas:

• Existing Suppliers
• New Suppliers
• Using recruitment agents
• Recruitment general
• Breaches of Money Laundering

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 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 as well as any relevant laws and professional codes of conduct applicable to us.
• We will ensure through awareness training that new and existing employees have a full understanding of the issues 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.

Last updated: November 2023