RSM UK1 is committed to social and environmental responsibility and to the fair and humane treatment of people both in its business and in its supply chains. This statement sets out the steps that RSM UK has taken in respect of the financial year ended 31 March 2018 to ensure that slavery and human trafficking are not taking place in any of its supply chains or in any part of its own business.
Organisational structure and supply chain
RSM UK is a leading provider of audit, tax and consulting services throughout the UK and is a member of the RSM network2. RSM UK provides services to its clients through a number of separate companies and limited liability partnerships within the group, the majority of which are subject to external regulation. Our supply chain includes for example office supplies and services, IT services, insurance services, provision of consumables and hotel suppliers.
Policies and Training
RSM UK is committed to working ethically and with integrity in all our business relationships. Respect for others and acting with integrity are two of the firm’s key values to which staff are expected to adhere.
The RSM UK Code of Conduct provides the ethical framework for the decisions RSM UK and its people make, individually and collectively. Its guidelines are intended to ensure that everyone within the business behaves in accordance with our values, ethical standards, professional regulations and applicable laws and so helps to maintain RSM UK’s reputation as an ethical and responsible business. The Code has been updated since the end of the financial year to reinforce the firm’s commitment to the fair and humane treatment of people in our business and our supply chains.
Our recruitment policy refers explicitly to RSM UK’s commitment to fulfilling its obligations under the Modern Slavery Act 2015 (the ‘Act’) and the HR team use a preferred supplier list of reputable recruitment agencies, a condition of inclusion on which is the provision of confirmation that the agencies themselves will not engage in any practice or omit to do any act or thing that amounts to modern slavery as defined under the Act.
RSM’s whistleblowing policy expressly refers to slavery and human trafficking and effective systems are in place designed to make it easy for workers to make disclosures without fear of retaliation and to make clear the process to be used should they have any concerns. Staff members are expected to report any concerns about slavery or human trafficking to management.
RSM UK’s expenses policy imposes personal responsibility on partners and staff for ensuring that expenses are only incurred with reputable persons or entities who engage in ethical business practices.
During the financial year ended 31 March 2018, mandatory training in relation to the Act was rolled out to all partners and staff. The programme included training on how to recognise modern slavery and human trafficking in day-to-day work and on the appropriate reporting channels within the firm. All new joiners are also required to complete this training.
Risk Assessment and Due Diligence Process
RSM UK has conducted an assessment of the risks of slavery and human trafficking, including country risks, sector risks and business partnership risks. The risk assessment consisted of two parts: analysis of RSM UK’s own business and analysis of RSM UK’s supply chain.
RSM UK conducts business in the UK, which is a low risk jurisdiction where slavery and human trafficking is prohibited and criminalised by law3.
RSM UK’s own business is the provision of professional advice, which is regarded as a low risk sector. To provide its services to clients, RSM UK relies on a stable, well-educated workforce, the majority of whom have professional qualifications and are members of professional bodies. All employees are engaged on written terms which comply with UK law, have a right to terminate their contract of employment and are paid at least the National Living Wage as well as receiving other fixed and flexible benefits. RSM UK is also subject to a high degree of sector-specific regulatory and other independent oversight. RSM UK is satisfied that the risk of slavery or human trafficking occurring in its own business is low.
RSM UK has undertaken a further review of its major suppliers, focusing on those in respect of which expenditure of at least £100,000 was incurred in the financial year to 31 March 2018, with a view to obtaining comfort as to their continuing commitment to compliance with the Act. As part of that review, for those suppliers who have published their own slavery and human trafficking statements, we have reviewed the steps taken to ensure that slavery and human trafficking is not taking place in their respective businesses, as outlined in their published statements. We have written to those major suppliers for whom we had not identified a published slavery and human trafficking statement, seeking specific confirmation of their continuing commitment not to engage in practices that could amount to modern slavery or human trafficking. Over 85% of the suppliers to whom we have written have either provided such confirmation or directed us to their published statement. The 2018 major supplier review has provided a significant degree of comfort that the risk of slavery or human trafficking occurring in RSM UK’s supply chain remains low.
Throughout the 2018/19 financial year, RSM UK is continuing to assess the risk of slavery and human trafficking in its own business and its supply chain and will publish a further statement following the financial year ending 31 March 2019.
This statement is made pursuant to s.54(1) of the Act and constitutes RSM UK’s Slavery and Human Trafficking Statement in respect of the financial year ended 31 March 2018. It has been approved by the Board of RSM UK Holdings Limited and the original has been signed by a Director, Martin Rodgers.
1 RSM UK means the UK group of companies and limited liability partnerships trading as RSM. This statement is made by RSM UK Holdings Limited, the ultimate holding company of RSM UK, 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 each of 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.