Christie Silvani takes a zero-tolerance approach to modern slavery and is committed to implementing and enforcing effective systems and controls to help ensure that modern slavery is not taking place anywhere in our own business or our supply chains.
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 Christie Silvani and its subsidiaries (the “firm”) have taken to prevent modern slavery and human trafficking within its business and supply chains.
Christie Silvani is an international, integrated and independent organisation, specialising in Audit, Advisory, Accountancy, Tax and Legal Services based in London, UK.
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 help 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 many areas within our business, including our supplier policies, contractual processes, training and reporting. Our Quality and Risk Team continues to work in conjunction with other areas of the firm (including our subject matter specialists 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 Global Code of Conduct sets out the way we wish to operate both between ourselves, between the firm and our clients and, also, between the firm and society. All our partners, staff and contractors are required to confirm they have read and understood our Global Code of Conduct as part of the annual compliance exercise.
Anti-Slavery and Human Trafficking Policy
Our Modern Slavery Act Policy, approved by our UK Executive Board, 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. Christie Silvani will be monitoring its use and effectiveness, dealing with any queries about it, and considering 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.
Suppliers
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. Therefore we are undertaking an ongoing review of our existing supplier contracts/agreements and assessing the risk associated with those suppliers, based on sector and jurisdiction. This includes 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; this includes additional due diligence over our new supplier take-on process.
We expect our suppliers to implement due diligence procedures for their 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 where appropriate 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 of 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.
Employees
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 Christie Silvani team members share and respect.
The majority of our workforce is employed on a permanent or contract basis. Our recruitment processes include direct advertising on our website, 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, right to work, references and evidence of qualifications where appropriate. Similar checks are also undertaken for contractors.
Whistleblowing
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. There were no reported incidents of slavery through this mechanism during the year.
Our Training and Awareness
A firm-wide mandatory awareness course has been set in place and all existing partners and staff are required to pass to gain accreditation. All new starters are required to complete this course as part of their induction programme. This mandatory training will be refreshed annually to ensure an up to date knowledge of the subject. The introduction of focussed training for those in the firm involved in contracts and procurement activities will also be considered.
Further Activities
In connection with the Act, we continue to consider our procedures to identify and manage, the risk from internal and external factors, including modern slavery and human trafficking.
Contact
If you have any further questions about our statement on Modern Slavery, contact us on 020 3286 5030 or send us an email at fs@silvani.co.uk.