Modern slavery statement

This statement is made on behalf of Francis Clark LLP (the Firm) and its subsidiaries 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 2027 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 nine 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 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 several subsidiary companies including Francis Clark Financial Planning Limited and Francis Clark Tax Consultancy Limited, all of which are covered by this statement.

The Firm has over 500 direct suppliers, the majority of which are based 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 its 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 to ensure that slavery and human trafficking is not taking place within our business or its supply chains.  All staff are expected to comply with this policy and to raise concerns where they suspect potential modern slavery risks.

As a firm regulated by the Institute of Chartered Accountants in England and Wales (ICAEW), we aim to uphold the professional standards and ethical requirements of the accountancy profession. These requirements shape how we conduct our work and our relationships with clients and suppliers, and they are embedded in our culture and development pathways.

Our commitment to ethical business practices is also reflected by our B Corp status, which aligns with our wider ESG priorities and reinforces our focus on acting responsibly for our people, clients, communities and the environment.

Assessing and managing risk

While the professional services sector presents a generally low risk of modern slavery within direct operations, the Firm recognises that certain supplier categories, including recruitment agencies, facilities management and outsourced services, may present an elevated risk and are subject to proportionate review.

In order to identify and mitigate risk, we aim to:

Employment

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 relevant laws and professional codes of conduct applicable to our business.

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 Act

Policies

The Firm has an Anti-Slavery and Human Trafficking Policy, a Whistleblowing Policy and a Responsible Purchasing Policy, which support our commitment to identify concerns and enable them to be raised and investigated appropriately; these policies are reviewed at least annually and updated as needed.  See also our Dignity at work statement.

These policies support, and are aligned with, our wider environmental, social and governance (ESG) approach, which aims to embed ethical and sustainable considerations into how we select, contract with and manage suppliers.

Monitoring and evaluation

Given the nature of our business and the predominately UK-based profile of our suppliers, we consider the risk of modern slavery within our operations and supply chain to be relatively low; however, we monitor and evaluate our approach through periodic, risk-based supplier reviews, consideration of any concerns raised through our Whistleblowing arrangements or otherwise, and annual review of this statement and related policies.

Training

The Firm is committed to ensuring that employees have an appropriate understanding of modern slavery risks and how to report concerns. Awareness of modern slavery and human trafficking forms part of the Firm’s wider compliance and ethics training framework.