(Financial Year End 31/12/2021)
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
In this context, this statement is to be read as applying to Grant Thornton Ireland* (Republic of Ireland, Northern Ireland and Isle of Man**) entities.
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, Isle of Man** and in Ireland who are forced to work illegally against their will. This is across many different sectors such as agriculture, hospitality (catering, etc.), construction, car wash services, retail and manufacturing (though COVID related restrictions may have seen some re-distribution to food supply chains and warehousing).5
Estimates of the number of victims of modern slavery in the UK, Isle of Man** 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, Isle of Man** 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, Northern Ireland and Isle of Man**) Anti-Slavery and Human Trafficking Policy so to assist staff (to those operating in a Republic of Ireland, Isle of Man** 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.
Grant Thornton is Ireland’s fastest growing professional services firm. Grant Thornton Ireland* is an unincorporated partnership under the Partnership Act, 1890 and comprises 56 partners (as of 31/12/2021). It is regulated by IAASA and PSCAI. The firm also conducts certain types of business through a number of incorporated entities based in the Republic Of Ireland and in Northern Ireland and Isle of Man**.
The firm employs over 2,000 people operating from offices in Dublin, Belfast, Cork, Galway, Kildare, Limerick, Longford and Isle of Man**.
Grant Thornton Ireland* is a full member firm of Grant Thornton International Limited (GTIL) which is a not-for-profit, non-practicing, international umbrella membership entity which is one of the world’s leading organisations of independently owned and managed accounting and consulting firms. GTIL is a global network of independent assurance, tax and advisory firms with more than 62,000 people in approx. 135 countries. Each of the member firms operates as a separate legal entity; and is not a worldwide partnership.
Further details on the structure of Grant Thornton Ireland* are available in our latest Transparency Report available on our website at https://www.grantthornton.ie/about/transparency-report/.
The policy of Grant Thornton Ireland* 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. Grant Thornton will review the continuation of business with individuals and organisations found to be involved in slavery, human trafficking, forced or child labour and retains the right to cease business with such individuals and organisations on this basis.
Grant Thornton Ireland* is committed to acting professionally and with integrity in all its business dealings and relationships whether in Ireland, UK, Isle of Man** or abroad.
In this context, Grant Thornton Ireland* has created a dedicated Anti-Slavery and Human Trafficking Policy.
We will review this policy and its operation in practice, at least on an annual basis.
Reporting knowledge or suspicion of slavery or human trafficking
All employees and partners within the firm have a statutory obligation to 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 the relevant Engagement Partner and to the Head of Risk, who will decide what further action, if any, is deemed necessary. If the issue reported also relates to knowledge or suspicion of money laundering or terrorist financing then a further report is to be submitted to the Money Laundering Reporting Officer (MLRO). In addition, the Grant Thornton Ireland* Whistleblowing Policy provides for alternative avenues for reporting, including in respect of suspicion or knowledge of slavery or human trafficking.
Partners and employees who raise concerns of slavery or human trafficking in good faith may do so without fear of discrimination or reprisal.
These provisions do not replace any legal reporting or disclosure requirements. Where statutory reporting requirements and procedures exist, these must be fully complied with.
Our Anti-Slavery and Human Trafficking Policy also includes contact details for the following:
During the financial year ended 31/12/2021 the Risk, Compliance & Professional Standards Team of Grant Thornton Ireland* did not receive any reports related to knowledge or suspicion of slavery or human trafficking.
Grant Thornton Ireland’s* client acceptance and ongoing monitoring procedures include detailed risk assessments of each client from an anti-money laundering, counter-terrorist financing and wider risk perspective. These include a review for potential publically available indications of previous or current involvement with criminality, including modern slavery and human trafficking. Staff are also to consider the client-reliant risk factors the (UK) National Crime Agency (NCA) identified in their Indicators of Modern Slavery and Human Trafficking in the Accountancy Sector guidance (with reference to the Appendix of the Anti-Slavery and Human Trafficking Policy).
Grant Thornton has included appropriate anti-slavery and human trafficking provisions into our Republic of Ireland and Northern Ireland terms of business with clients.
Grant Thornton Ireland* has procedures in place pertaining to our employment practices.
- Robust recruitment processes in line with Republic of Ireland, Northern Ireland (UK) and the Isle of Man** 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 our firm is 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, Grant Thornton Ireland* considers 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, UK and the Isle of Man** countries with a relatively lower risk of modern day slavery and human trafficking.
From a risk management perspective, we have identified areas we need to develop in conjunction with our supply chain, and a risk-based approach is under development. This approach is to include identifying and reviewing suppliers and vendors that fall within industries and/or countries that can carry higher risk, including in respect of modern day slavery and human trafficking. Grant Thornton Ireland* has developed measures to assist in the review and management of these areas of risk, including an enhanced supplier and vendor take-on review and ongoing monitoring process, which is handled by the Legal team.
This review and monitoring process is to take into account the relevant risk factors the (UK) National Crime Agency (NCA) identified in their Indicators of Modern Slavery and Human Trafficking in the Accountancy Sector guidance (with reference to the Appendix of the Anti-Slavery and Human Trafficking Policy).
Related policies and documents
In addition to the Anti-Slavery and Human Trafficking Policy mentioned above Grant Thornton Ireland* has additional related policies and documents.
The Grant Thornton Ireland* Whistleblowing Policy is highlighted to employees and partners on a reoccurring basis. This policy facilitates and encourages employees and partners to raise concerns or disclose information, which relates to wrongdoing, illegal practices or unethical conduct, which may come to their attention through work (including concerns that may relate to modern slavery and human trafficking). This includes the facility for anonymous reporting.
Grant Thornton Ireland* have a number of further policies and documents which reflect our objective to act ethically and in line with our legal and regulatory obligations with regard to our employees, clients and our business relationships.
- Grant Thornton (Ireland*) Transparency Report (available on the Grant Thornton website here)
- Grant Thornton International Ethics and Quality Control Manual
- Grant Thornton (Republic of Ireland, Northern Ireland and Isle of Man**) Staff Handbooks
- Grant Thornton Ireland* Anti-Money Laundering Compliance Manual (and equivalent Isle of Man** documentation)
- Grant Thornton Ireland* Anti-Bribery and Corruption Policy
These policies and documents will continue to be reviewed on, at minimum, an annual basis.
We want to help our employees, partners, clients and suppliers to understand more about these issues and understand how to report any suspicions they may have related to modern slavery and human trafficking.
The topic of Modern Slavery, and our associated Anti-Slavery and Human Trafficking Policy, continues to be flagged in the induction training undertaken by new staff members starting with Grant Thornton Ireland*.
We flag each update of this Statement and of the associated Anti-Slavery and Human Trafficking Policy to all staff members.
It is also intended to further highlight the issue of Modern Slavery, as well as our Statement and Policy, to all staff members around (UK) Anti-Slavery Day11 (18th of October of each year).
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 Ireland’s* Anti-Slavery and Human Trafficking Policy among relevant employees and partners.
Grant Thornton Ireland* 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.
Grant Thornton Ireland* shall take responsibility for this statement and its objectives, and this statement will be reviewed and updated as appropriate.
Partner, Head of Risk
*Republic of Ireland, Northern Ireland and Isle of Man Grant Thornton entities that are members of Grant Thornton Ireland.
**Grant Thornton Limited and Grant Thornton Specialist Services (Isle of Man) Limited became part of Grant Thornton Ireland in November 2021.
1 (UK) Modern Slavery Act 2015 (here) and the guidance issued under section 54(9) of that Act (here) and additional (UK) Home Office guidance (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) and 2021 (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 Modern Slavery Helpline (here)
10 Migrant Rights Centre Ireland (here)
11 (UK) Anti-Slavery Day website (here)
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