We¹ recognise as a firm that slavery and human trafficking (modern slavery) is a serious issue within our society. We are committed to acting ethically and with integrity in our business dealing and relationships and to the fair and humane treatment of people both in our business and in our supply chains.
This statement sets out the steps that we have taken in respect of the financial year ended 31 March 2023 to contribute towards ensuring that modern slavery is not taking place in any of our supply chains or in any part of our own business.
Organisational structure and supply chain
We are a leading provider of audit, tax and consulting services throughout the UK, and a member of the RSM network². Our services are provided via separate companies and limited liability partnerships within our group, most of which are externally regulated.
Our suppliers include office supplies and services, IT and software services, professional services such as recruitment, legal and insurance, and travel agents and hotels.
Our key values include respect for others and acting with integrity. We expect this of all our people³.
The RSM UK Conduct and Culture Statement provides the ethical framework for the decisions we make, both individually and collectively. It sets out our values as a firm. It aims to ensure that our people uphold our values and ethical standards, and comply with professional regulations and applicable laws. The Conduct and Culture Statement reinforces our commitment to the fair and humane treatment of people in our business and our supply chains, and helps maintain our reputation as an ethical and responsible firm.
We also have the following key policies that are relevant to modern slavery:
- Recruitment – we take a robust approach to recruitment, including conducting ‘eligibility to work in the UK’ checks for all employees to safeguard against human trafficking or individuals being forced to work against their will. We only use reputable recruitment agencies, all of whom have had to confirm that they will not engage in any practice that would be considered modern slavery under UK law.
- Speaking up – our policies ensure that all our people know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisal. Our people are openly encouraged to report any concerns about modern slavery, including any involving clients or suppliers.
- Health and safety – we aim to ensure that we provide a safe working environment for those working on our premises. The health and wellbeing of our staff is important to us, and the firm supports this via a number of employee wellbeing initiatives.
- Procurement – our policies impose personal responsibility on our people to make sure that expenses are only incurred with reputable suppliers who engage in ethical business practices.
- Anti-Bribery – we have a zero tolerance stance on bribery and all our people receive training to recognise and avoid bribery. We also commit to take appropriate and firm action against any individual involved in bribery. This helps avoid poor procurement practices and the use of unethical suppliers.
All new joiners are required to complete training on modern slavery as part of their onboarding process. This training covers how to recognise indicators of modern slavery and human trafficking (including the ILO indicators) in day-to-day work, especially when dealing with clients and suppliers, as well as how to report any concerns.
We periodically run refresher training on modern slavery that is mandatory for all our people. The refresher training was last rolled out in the financial year ending 31 March 2022, and will be next rolled out across the firm prior to the publication of our statement for the financial year ending 31 March 2024.
Risk assessment and due diligence process
We conduct business predominantly in the UK, a lower risk jurisdiction where slavery and human trafficking is prohibited and criminalised by law.
Our business is providing professional advice, regarded as a low risk sector. In providing our services, we rely on a stable, well-trained workforce, the majority of whom have professional qualifications and are members of professional bodies. All our employees have formal employment contracts, which they can terminate. They are all paid at least the national living wage as well as receiving other fixed and flexible benefits. We are also a regulated business and are subject to substantial independent oversight. We are satisfied that the risk of slavery or human trafficking occurring in our own business is low.
We have again reviewed our major external suppliers4, with a view to obtaining confirmation as to their continuing commitment to compliance with tackling modern slavery. We reviewed the published slavery and human trafficking statements of those major suppliers that had produced one. We also wrote to those major suppliers for whom we had not identified such a published statement, seeking specific confirmation of their continuing commitment not to engage in practices that could amount to modern slavery. Around 90% of our major external suppliers either had such a statement or provided such confirmation. The 2023 major supplier review has provided a significant degree of comfort that the risk of modern slavery occurring in RSM UK’s supply chain remains low.
Supplier Code of Conduct
Our Supplier Code of Conduct sets out our expectations of our suppliers in several areas including modern slavery, and has been made available on our website. In summary, its key requirements in relation to modern slavery are that our suppliers:
- engage their staff on written terms which comply with law, explicitly state their working hours and compensation and contain a right for them to terminate;
- pay all remuneration owed to their staff without delay and in accordance with law;
- take a robust and proactive approach to recruitment, and to only use reputable recruitment agencies;
- provide training to their staff on modern slavery issues;
- have policies to encourage their staff to raise concerns without fear of reprisal; and
- have policies to make sure that the suppliers they use are reputable and engage in ethical business practices.
Throughout the current financial year, we intend to continue engaging with our top 50 external suppliers5, who represented around half of our total spend on suppliers across the RSM UK group for the financial year ending 31 March 2022. We will be asking each of them to either acknowledge our Supplier Code or provide alternative assurance that they comply with it. As of the date of this statement, 27 of these top 50 external suppliers have done so.
Following this process, we will review the implementation of our Supplier Code to ensure it is meeting our requirements, and then consider expanding the scope to cover a wider range of our key suppliers.
We continue to assess the risk of slavery and human trafficking in our own business and our supply chain and will publish a further statement following the current financial year (ending 31 March 2024).
This group statement constitutes RSM UK’s slavery and human trafficking statement in respect of the financial year ended 31 March 2023. It is made pursuant to s.54(1) of the Modern Slavery Act 2015 and covers RSM UK Holdings Limited and the following RSM UK entities which are required to publish statements under the Act:
Arrandco Investments Limited
RSM UK Audit LLP
RSM UK Corporate Finance LLP
RSM UK Group LLP
RSM UK Management Limited
RSM UK NLT Limited
RSM UK Risk Assurance Services LLP
RSM UK Tax and Accounting Limited
RSM UK Tax and Advisory Services LLP
1 ‘We’ and ‘our’ in this statement refers to the UK group of companies and limited liability partnerships trading as RSM. RSM UK Holdings Limited would not have itself satisfied the threshold in the Modern Slavery Act 2015 during the financial year ended 31 March 2023, but it is considered appropriate that it makes this statement as the current ultimate operational holding company. It makes this statement on behalf of itself and its subsidiaries.
2 RSM is the trading name used by the members of the RSM network. Each member of the RSM network is an independent accounting and consulting firm which practises in its own right. The RSM network is not itself a separate legal entity of any description in any jurisdiction. The RSM network is administered by RSM International Limited, a company registered in England and Wales (company number 4040598) whose registered office is at 50 Cannon Street, London, EC4N 6JJ.
3 When we say ‘people’ in this statement we generally mean our partners and consultants as well as our employees. Note that a few consultants may not have access to RSM systems and so may not, for example, receive all the training the rest of our people receive.
4 This means those suppliers outside the RSM UK group or RSM international network with whom we spent at least £100,000 during the financial year to 31 March 2023 (disregarding UK regulatory and other UK public bodies, and individuals), to the extent we continued to have a relationship with them at the time of the review.
5 Please see note 4 for what we generally mean by external suppliers – i.e. those suppliers outside the RSM UK group or RSM international network (disregarding UK regulatory and other UK public bodies, and individuals), to the extent we continued to have a relationship with them at the time of the review. However, in addition, we have approached and received a response from the Institute of Chartered Accountants in England and Wales (ICAEW).