Modern Slavery Statement

Introduction

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”.1

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.1

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 2013.2

Modern slavery

Modern slavery is an international crime affecting an estimated 40.3 million individuals3 around the world.  This global issue transcends age, gender and ethnicities; it is estimated that 1 in 4 victims of modern slavery are children and that 3 quarters are women and girls4.  

 

“Modern slavery” refers to the offences of human trafficking, slavery, servitude, and forced or compulsory labour. This can then be considered under five headings:

  • the sexual exploitation of adults;

  • the trafficking of adults into conditions of labour exploitation;

  • the trafficking of adults into conditions of criminal exploitation;

  • the trafficking of minors into conditions of sexual, criminal or labour exploitation;

  • other forms of exploitation.5

 

“Human trafficking” is a global crime that trades in people and exploits them for profit.. “Human trafficking” is defined in the UN Trafficking in Persons Protocol, which supplements the United Nations Convention against Transnational Organized Crime, as “the recruitment, transport, transfer, harbouring or receipt of a person by such means as threat or use of force or other forms of coercion, abduction, fraud or deception for the purpose of exploitation”. 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.6

 

Modern slavery includes victims who have been brought from overseas and vulnerable people in the UK and in Ireland who are forced to work illegally against their will across many different sectors such as agriculture, hospitality (catering, etc.), construction, car wash services, retail and manufacturing.5

 

Estimates of the number of victims of modern slavery in the UK and Republic of Ireland have markedly increased in recent years. The 2018 Global Slavery Index3 estimated approx. 136,000 such individuals in the UK, with approx. 8,000 in the Republic of Ireland. The UK National Crime Agency (NCA) annual National Strategic Assessments of Serious and Organised Crime indicate significantly increasing numbers of modern slavery related cases referred through relevant reporting/referral mechanisms, and numbers of associated police investigations, each year.5 

 

It has been estimated that globally modern slavery generates as much as $150bn (£116bn) in profits every year with more than a third of these profits generated in developed countries, including the UK and the Republic of Ireland.7

The (UK) National Crime Agency (NCA) identified in their Indicators of Modern Slavery and Human Trafficking in the Accountancy Sector8 guidance what they consider the key areas where they deems there to be greater risk and visibility of modern slavery and human trafficking. This NCA guidance is included as an Appendix in the Grant Thornton Ireland (Republic of Ireland and Northern Ireland) Anti-Slavery and Human Trafficking Policy so to assist staff (both operating in a Republic of Ireland or a UK Northern Ireland context) better identify potential real-world risks or actual instances in relation to modern slavery and human trafficking. That NCA guidance has also been considered and has influenced the content of this statement and of the policy, as well as communications and training relating to this topic.

 

Our structure

We are a small, privately owned limited company with offices in Dublin.

We employ a team of three and work with a small group of trusted partners and advisors based in Ireland and the UK.

 

Our policy

The policy of Inspiring Change 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. We’ll immediately terminate business with individuals and organisations found to be involved in slavery, human trafficking, forced or child labour.

 

We are committed to acting professionally and with integrity in all our business dealings and relationships whether in Ireland, UK or abroad.

Reporting knowledge or suspicion of slavery or human trafficking

It’s incumbent on everyone who works with or for Inspiring Change to immediately 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 Managing Director who will decide what further action, if any, is deemed necessary.

Employees or partners who raise concerns of slavery or human trafficking in good faith may do so without fear of discrimination or reprisal.

 

Clients

We don't and won’t work with organisations or clients who we believe to be in contravention of the Modern Slavery Act.

We include appropriate anti-slavery and human trafficking provisions into our Republic of Ireland and Northern Ireland terms of business with clients.

Employment procedures

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.

 

Supply chain/ Procurement

We recognise that we’re 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, we consider 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 with a relatively lower risk of modern day slavery and human trafficking.

We continue to consider on an ongoing basis ways to further enhance awareness on the issues of slavery and human trafficking and of Grant Thornton’s Anti-Slavery and Human Trafficking Policy among relevant employees and partners.

 

Looking forward

We will continue to develop and implement the measures mentioned above in respect of our supply chain.

 

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 2021 and beyond.

 

Inspiring Change and our people will take responsibility for this statement and its objectives, and we’ll review and update it as appropriate.

Signed

 

 

 

 

 

Scott McInnes

Managing Director

Inspiring Change Ltd

Sources:

1.   (UK) Modern Slavery Act 2015 (here) and the guidance issued under section 54(9) of that Act (here)

2.  (Republic of Ireland) Criminal Law (Human Trafficking) Act 2008 (here) & Criminal Law (Human Trafficking) (Amendment) Act 2013 (here)

3. As per the 2018 Global Slavery Index (here);

Executive Summary (here)

United Kingdom: Findings (here) & Country Data (here)

Ireland: Country Data (here)

4.  International Labour Organization (ILO) Global Estimates of Modern Slavery (here)

5.  (UK) National Crime Agency (NCA) National Strategic Assessment of Serious and Organised Crime 2019 (here) and 2020 (here).

6.  United Nations Office of Drugs and Crime (UNODC) – Human Trafficking (here) and Human Trafficking FAQs (here)

7.  International Labour Organization (ILO) Global Estimates of Modern Slavery (forced labour and forced marriage) (here and here)

8.  Indicators of Modern Slavery and Human Trafficking in the Accountancy Sector (here)

9.  (UK) Anti-Slavery Day website (here)  

Inspiring Change is not responsible for the content or other aspects of non-Grant Thornton websites.

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