Mazars LLP and its subsidiaries
This statement has been published in accordance with section 54(1) of the Modern Slavery Act 2015 (the “Act”). It sets out the steps that Mazars LLP and its subsidiaries (the “firm”) have taken to prevent modern slavery and human trafficking within its business and supply chains. The statement applies for the financial year ended 31 August 2016.
Mazars is a global integrated Partnership, specialising in audit, accounting, legal, tax and advisory services. We operate in 77 countries, and with correspondent and representative offices, we operate in a further 13 countries. In each country in which we have a member of our integrated Partnership, one or more separate legal entities exist. In the UK, the member entity of the Mazars Group is Mazars LLP, a Limited Liability Partnership. Mazars LLP provides audit, accounting, tax and advisory services.
For the purpose of the Act, the Mazars entities in our global network, and correspondent and representative offices, are part of our supply chain. For further details on our structure, and the governance of our UK firm, please refer to our published Transparency Report (Mazars UK Transparency Report 2015/2016).
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chains.
We are therefore continuing to implement appropriate controls across a number of areas within our business, including our supplier policies, contractual processes, training and reporting. Our Legal Counsel, and Quality and Risk Team, continue to work in conjunction with other areas of the firm (including HR and our subject matter expert in Human Rights and Modern Slavery) to help ensure the intent of the Act is met within our own business and our supply chains.
We also believe in the importance of transparency: for our clients, our people and broader society. Our Code of Conduct is entitled “Our Commitment to Quality and Integrity” (Our values culture) and sets out the way we wish to operate both between ourselves, between the firm and our clients and, also, between the firm and society.
Business. For Good
As organisations adapt to the complexities of globalisation, a growing strain on natural resources and the environment, the influx of new technologies, use of social media and increased transparency, one thing is clear: a societal approach to business and ethical behaviour is more important than ever. Business. For Good is our global initiative that encourages business leaders to think and act long-term in order to enhance business performance and pursue profit responsibly for the benefit of companies and their stakeholders including the wider society.
We are driving companies and business leaders to manage and address human rights issues in business. Our award-winning team of professionals helps embed a genuine respect for human rights throughout an organisation, promoting respect for the rights of individuals that could be impacted by business activities. It is not just an initiative that we promote externally: the ethos lies at the heart of our business and is reflected in our actions every day.
Within our firm we are committed to paying people fairly and properly for the work that they perform.
Our Code of Conduct applies to all staff and contains our standards and values. Strong values have been at the heart of our organisation since its creation. They guide us in our daily actions, providing a common base of values that all Mazars’ team members share and respect.
Our six values include the following three specific values relating to our work and ethos, and how it affects the wider global environment:
- Integrity - Ethical and moral rigour guide how we work and assist our clients;
- Responsibility - We treat the challenges of our clients as our own and we care about how our work may affect our communities; and
- Diversity and respect for individuals - Looking beyond borders and cultural differences, we make respect for the individual the cornerstone of all human relations.
Our standards include the following:
- We act with integrity and comply with the law, professional standards and the firm’s policies and procedures applicable to our work;
- We consult when questions of ethics arise;
- We speak up when we see or hear of behaviour that causes us concern on ethical grounds or fails to uphold our values. Team members who speak up in good faith are assured that they will not suffer any adverse consequences as a result of their doing so; and
- We develop and promote thought leadership on issues of importance to the business, financial communities and wider society, including in the area of human rights.
The majority of our workforce is employed on a permanent or contract basis. Our recruitment processes include direct advertising on our web-site, using reputable agencies, and also direct referrals from staff members. All employees who join the firm are subject to checks, including the verification of identity, references and evidence of qualifications where appropriate. Similar checks are also undertaken for contractors.
We encourage all our staff, clients and other parties to report any concerns they may have in relation to a risk, malpractice or wrongdoing that affects others such as clients, staff, the firm, suppliers or the public. Our whistleblowing procedure is designed to ensure that people can make disclosures without fear of retaliation. We have launched a confidential hotline (Whistleblowing Policy) run by an external and independent company to support this initiative.
Our Training and Awareness
During the financial year we held a number of awareness seminars, attended by both clients and staff, to provide a high level understanding of the risks of modern slavery in business and supply chains. This was supported by newsletters and e-Bulletins issued across the firm.
Further Steps Taken
In connection with the Act we continue to consider where our business and supply chain is most at risk, including a programme of activities to identify and manage risks arising from modern slavery and human trafficking.
The supply chain that supports our business comprises a wide range of suppliers, from smaller businesses to global companies, across many jurisdictions, including those where there is a higher risk of forced labour. Our supply chain includes products and services from IT hardware and software, office design, fit-out and maintenance, recruitment agents, cleaning and catering services, through to outsourced services such as our IT service desk.
Since our year end we have put in place new risk-based controls, focussing on those areas which will have the most impact. To date we have already acted upon the following areas:
Anti-Slavery and Human Trafficking Policy
An Anti-Slavery and Human Trafficking Policy has been approved by our UK Executive Board. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. By implementing this policy, Mazars will be monitoring its use and effectiveness, dealing with any queries about it, and consider internal control systems and procedures to ensure they are effective in countering modern slavery.
The policy states that our zero-tolerance approach to modern slavery will be communicated to suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter. In addition, we may terminate our relationship with individuals and organisations working on our behalf if they breach this policy.
Our UK Executive Board has approved a clause to be included in supplier contracts or other terms. The clause specifies that “the Supplier shall comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes from time to time in force including but not limited to the Modern Slavery Act 2015; and comply with the Anti-slavery policy and maintain throughout the term of this agreement its own policies and procedures to ensure its compliance”. The clause is to be included in future supplier contracts or other terms.
We expect our suppliers to implement due diligence procedures for its permitted direct subcontractors, and suppliers and other participants in its supply chains, to ensure that there is no slavery or human trafficking in its supply chains. The clause enables the firm to undertake audits of suppliers’ records and any other information and to meet with suppliers’ personnel to review their compliance with its obligations under this clause. The clause also gives the firm the right to terminate the agreement with immediate effect if the supplier commits a breach of the anti-slavery policy or this clause or applicable anti-slavery and human trafficking laws, statutes, regulations and codes from time to time in force including but not limited to the Modern Slavery Act 2015.
Our revised approach to enterprise-wide risk management has resulted in the implementation of changes to our procedures to identify, and manage, risk from internal and external factors, including modern slavery and human trafficking. We have undertaken a review and revision of our Enterprise Risk Management Framework, and as part of this, our categories of risk have been extended to more explicitly report on, for example, governance and legal risks, which reflects the added emphasis and importance of risks in these areas and the potential impact they have on the success of the firm, and society as a whole.
Training and Awareness
A firm-wide mandatory awareness course was released in January 2017, which all existing partners and staff are required to pass to gain accreditation. All new starters will be required to complete this course as part of their induction programme.
Future Activities Planned
Our future programme of activities includes:
- Reviewing our existing supplier contracts / agreements and assessing the risk associated with those suppliers;
- Reviewing our procurement process from sourcing to contract award, to identify how we can reduce the potential for risk of modern slavery in our supply chain (for example, additional due diligence over our new supplier take-on process, to include specific questions on compliance with the Act); and
- Introducing focussed training for those in the firm involved in contracts and procurement activities.
This statement has been approved by the UK Executive Board on behalf of Mazars LLP. It will be reviewed and updated annually.
UK Senior Partner, Mazars LLP
If you have any further questions in relation to our statement on Modern Slavery, contact us on 0207 063 4000 or via our on-line Enquiry Form (Enquiry Form). Alternatively, if you have any concerns about modern slavery or human trafficking taking place in our business (or supply chain) contact our Ethics Partner at Greg.Hall@mazars.co.uk or our Whistleblowing hotline (Whistleblowing Policy).