Per the (UK) Modern Slavery Act 2015 all bodies corporate and partnerships who (irrespective of where they are incorporated) (1) carry on a business, or part of a business, in the UK supplying goods or services, and (2) have a consolidated global turnover of above £36 million (or Euro equivalent) per annum, are required to prepare and publish an annual “Slavery and Human Trafficking Statement”. This statement must set out the measures an organisation has taken during its financial year to ensure that slavery or human trafficking is not taking place in any of its supply chains or within itself.
The Republic of Ireland has similar legislation, primarily the Criminal Law (Human Trafficking) Act 2008, as amended by the Criminal Law (Human Trafficking) (Amendment) Act 2013.
In this context, this statement is to be read as applying to the Grant Thornton Ireland (Republic of Ireland and Northern Ireland) entities.
Modern slavery is an international crime affecting an estimated 45.8 million individuals1 around the world. It is a growing global issue that transcends age, gender and ethnicities. It includes victims who have been brought from overseas and vulnerable people in the UK and in Ireland who are forced to illegally work against their will across many different sectors such as agriculture, hospitality, construction, retail and manufacturing.
The (UK) Modern Slavery Act 2015 categorises offences of slavery, servitude and forced or compulsory labour and human trafficking. Although human trafficking often involves an international cross-border element it is also possible to be a victim of modern slavery within your own country. There are several broad categories of exploitation linked to human trafficking, including sexual exploitation, forced labour, domestic servitude, organ harvesting, child related crimes, forced marriage and illegal adoption.
The (UK) National Crimes Agency estimates that there are tens of thousands of victims of modern slavery and human trafficking in the UK2. The 2016 Global Slavery Index1 estimated approx. 12,000 such individuals in the UK, with approx. 800 in the Republic of Ireland.
Grant Thornton is Ireland’s fastest growing professional services firm. Grant Thornton Ireland is an unincorporated partnership under the Partnership Act, 1890 and comprises 49 partners (as of 1/10/2017). It is regulated by IAASA and PSCAI. The firm also conducts certain types of business through a number of incorporated entities based in the Republic Of Ireland and in Northern Ireland.
The firm employs over 1,000 people operating from offices in Dublin, Belfast, Cork, Galway, Kildare, Limerick and Longford.
Grant Thornton Ireland is a member firm of Grant Thornton International Ltd (GTIL) which is one of the world’s leading organisations of independently owned and managed accounting and consulting firms.
Further details on the structure of Grant Thornton Ireland are available in our latest Transparency Report available on our website here.
The policy of Grant Thornton is to conduct all of our business in an honest and ethical manner, and to comply with all applicable legislation. We strive to ensure that neither modern slavery nor human trafficking supports our supply chain or our businesses; this objective is implicit in our policies and procedures. We aim for a zero-tolerance approach to violations of anti-slavery and human trafficking laws. If breaches of these laws are found within our supply chain we will look to support organisations in their efforts to comply with the applicable legislation. However Grant Thornton will review the continuation of business with individuals and organisations found to be involved in slavery, human trafficking, forced or child labour and retains the right to cease business with such individuals and organisations on this basis. Grant Thornton is committed to acting professionally and with integrity in all its business dealings and relationships whether in Ireland, UK or abroad.
In this context Grant Thornton has created a focused Anti-Slavery and Human Trafficking Policy.
We will review this policy and its operation in practice, at least on an annual basis.
Reporting knowledge or suspicion of slavery or human trafficking
All employees and partners within the firm have a statutory obligation to report knowledge or suspicion of slavery or human trafficking. Any genuine suspicion or knowledge of slavery or human trafficking is to be immediately reported to the relevant Engagement Partner and to the Head of Risk, who will decide what further action, if any, is deemed necessary. If the issue being reported also relates to knowledge or suspicion of money laundering or terrorist financing then a further report will be submitted to the Money Laundering Reporting Officer (MLRO). In addition the Grant Thornton Whistleblowing Policy provides for alternative avenues for reporting suspicion or knowledge of slavery or human trafficking.
Partners and employees who raise concerns of slavery or human trafficking in good faith may do so without fear of discrimination or reprisal.
These provisions do not replace any legal reporting or disclosure requirements. Where statutory reporting requirements and procedures exist these must be complied with fully.
Grant Thornton’s client acceptance procedures include a detailed risk assessment of each client from an anti-money laundering, counter-terrorist financing and wider risk perspective. This includes a review for potential publically available indications of previous or current involvement with criminality, including modern slavery and human trafficking.
Grant Thornton is developing appropriate anti-slavery and human trafficking provisions for inclusion into our Republic of Ireland and Northern Ireland terms of business with clients.
Grant Thornton has procedures in place pertaining to our employment practices:
- Robust recruitment processes in line with Republic of Ireland or Northern Ireland (UK) employment law (as applicable), including “right to work” document checks, contracts of employment, and checks to ensure all employees are above minimum working age (16).
- Market-related pay and reward, which is reviewed annually and linked to professional services firms benchmarks.
- An extensive benefits package, providing additional health and welfare options to support our employees (and families) lifestyle choices.
Supply chain/ Procurement
We recognise that our firm is exposed to a greater slavery and human trafficking risk when dealing with suppliers of products and services, particularly those who have operations and suppliers in other territories. However Grant Thornton considers that we and the majority of our suppliers are not in industries with a high risk of modern day slavery. In addition our supply chains are primarily confined to Ireland and the UK, countries within which, there is also a relatively lower risk of modern day slavery and human trafficking.
In this context we have identified areas we need to develop in conjunction with our supply chain, and a risk based approach is being developed. This is to identify and review supply chains that fall within industries and/or countries that can carry a higher risk of modern day slavery and human trafficking.
Grant Thornton is in the process of developing the following measures to review and manage this area of risk:
- Responsible purchasing policy;
- Supplier code of conduct;
- Risk analysis framework of our supply chain;
- Appropriate initial due diligence for and ongoing monitoring of suppliers; and
- Commitment to collaborate closely with suppliers to help them understand and work towards anti-slavery and human trafficking standards.
Related policies and documents
In addition to the Anti-Slavery and Human Trafficking Policy mentioned above Grant Thornton has additional related policies and documents.
The Grant Thornton Whistleblowing Policy is highlighted to employees and partners on a reoccurring basis. This policy facilitates and encourages employees and partners to raise concerns or disclose information which relates to wrongdoing, illegal practices or unethical conduct which may come to their attention through work (including concerns that may relate to modern slavery and human trafficking).
Grant Thornton have a number of further policies and documents which reflect our objective to act ethically and in line with our legal and regulatory obligations with regard to our employees, clients and our business relationships:
- Grant Thornton (Ireland) Transparency Report (available on the Grant Thornton website here [ 1191 kb ] [ 1191 kb ]);
- Grant Thornton International Ethics and Quality Control Manual;
- Grant Thornton (Republic of Ireland and Northern Ireland) Staff Handbooks;
- Grant Thornton Anti-Money Laundering Compliance Manual; and
- Grant Thornton Anti-Bribery and Corruption Policy.
These policies and documents will continue to be reviewed on, at minimum, an annual basis.
We want to help our employees, partners, clients and suppliers to understand more about these issues and how to report any suspicions they may have related to modern slavery and human trafficking.
We are developing training on the issues of slavery and human trafficking and Grant Thornton’s Anti-Slavery and Human Trafficking Policy to be delivered to all our employees and partners on a periodic basis.
We are also planning additional training for employees and partners specifically involved in ensuring compliance with this Policy.
Going forward Grant Thornton will continue to develop the measures mentioned above in respect of our supply chain.
More generally our approach to modern slavery and human trafficking risk will continue to evolve and we will continue to mitigate these risks through the provisions mentioned above during 2017 and beyond.
Grant Thornton shall take responsibility for this statement and its objectives which will be reviewed and updated as appropriate.
Partner, Head of Risk
Grant Thornton Ireland
1 As per the 2016 Global Slavery Index; https://www.globalslaveryindex.org/findings/.
Grant Thornton is not responsible for the content or other aspects of non-Grant Thornton websites.