Modern Slavery Statement

Introduction

This statement sets out MHA’s actions to understand all potential modern slavery risks related to our business and to put in place steps that are aimed at ensuring there is no slavery or human trafficking in our business or our supply chains. As a responsible business, we’re committed to upholding internationally recognised human rights through the way we operate.

This statement relates to actions and activities during the financial year 1 April 2021 to 31 March 2022.

MHA has developed this statement to comply with the UK Modern Slavery Act 2015. It outlines our commitment to preventing modern slavery across our Firm and supply chains. Section 54 of the Act requires companies to be more transparent about how they tackle modern slavery in their supply chains. This includes detailed information on structures and relevant policies and systems. MHA recognises that it has a responsibility to take a robust approach to slavery and human trafficking. We are absolutely committed to preventing slavery and human trafficking in our corporate activities, and to ensuring that our supply chains are free from slavery, human trafficking, exploitation and discrimination.

MHA’s structure and supply chains

We are a top 15 UK accounting Firm, offering a full range of compliance and advisory services to entrepreneurial businesses, groups and multinationals with operations in the UK and to offshore investment funds.

MHA has over 106 Partners and around 1152 colleagues in 18 offices in London, the South East, East Anglia, the Midlands, the North West and in the Cayman Islands.

MHA is the UK member of Baker Tilly International, one of the world’s largest leading networks of independent accountancy and business advisory firms. The members of Baker Tilly International are independent and separate legal entities operating in their respective territories.

MHA is not Baker Tilly International’s agent and does not have authority to bind Baker Tilly International or act on Baker Tilly International’s behalf. None of Baker Tilly International, MHA nor any of the other member firms of Baker Tilly International has any liability for each other’s acts or omissions.

MHA doesn’t operate in high risk areas and we don’t consider any of our activities to be at high risk of slavery or human trafficking.

Modern slavery and human trafficking statement

This statement sets out MHA’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our business and supply chains.

As a responsible business, MHA is committed to upholding the internationally recognised human rights through the way we operate. This statement relates to actions and activities during the financial year 1 April 2021 to 31 March 2022. MHA developed this statement to comply with section 54 (1) of the UK Modern Slavery Act 2015 (the Act). It outlines our commitment to preventing modern slavery across our Firm and supply chains. The Act requires companies to be more transparent about how they tackle modern slavery in their supply chains. This includes detailed information on structures and relevant policies and systems.

MHA recognises that it has a responsibility to take a robust approach to slavery and human trafficking. We are absolutely committed to preventing slavery and human trafficking in our corporate activities, and to ensuring that our supply chains are free from slavery, human trafficking, exploitation and discrimination.

MHA’s structure and supply chains

This statement covers the activities of the MHA network in the United Kingdom see “Details of MHA UK entities” page. We are a top 15 UK accounting firm, offering a full range of compliance and advisory services to entrepreneurial businesses, groups and multinationals with operations in the UK and to offshore investment funds. MHA has over 106 Partners and around 1152 colleagues in [eleven] offices in London, the South East, East Anglia, the Midlands, the North West and in the Cayman Islands.

MHA is the UK member of Baker Tilly International, one of the world’s largest leading networks of independent accountancy and business advisory firms. The members of Baker Tilly International are independent and separate legal entities operating in their respective territories. MHA is not Baker Tilly International’s agent and does not have authority to bind Baker Tilly International or act on Baker Tilly International’s behalf. None of Baker Tilly International, MHA nor any of the other member firms of Baker Tilly International has any liability for each other’s acts or omissions.

MHA doesn’t operate in high risk areas and we don’t consider any of our activities to be at high risk of slavery or human trafficking.

Risk assessments

Risk assessments for all our suppliers are carried out by individual offices on an ad-hoc basis as and when new suppliers need to be engaged or a service is to be re-tendered. The majority of our suppliers are through FISCO, a provider of workplace services and products. They have their own Modern Slavery Statement in place and also use a Supplier Code of Conduct. The remainder have a long-standing relationship with MHA, forming trust and confidence in their practices backed by their reputation in the marketplace. We seek to obtain either their own Modern Slavery Statement or the completion of a Modern Slavery Assessment setting out their assurance that they are compliant with the Act. We have obtained these from the vast majority of current suppliers and will continue to seek them from the others.

Risk assessments of recruitment agencies we work with are undertaken by the recruitment team. We have long-standing relationships with the majority of the agencies we work with and we are assured of their practices from previous experience and their reputation in the marketplace. We have obtained written assurance from all recruitment agencies we are working with that they are compliant with the Act and have also set out this requirement in our Heads of Terms. We will continue to do this for any new agencies we use.

Right to Work in the UK checks are conducted by ourselves for all new employees when they start working for MHA. Temporary workers from agencies are always thoroughly checked prior to appointment. All employees are given an employment contract and are made aware of all internal policies and procedures as well as their statutory entitlements and other benefits.

Incidents in the previous financial year

No incidents of modern slavery or human trafficking were reported to MHA in the previous financial year.

Due diligence

MHA undertakes due diligence when considering taking on new clients and suppliers and regularly reviews its existing clients and suppliers.

Relevant policies

MHA has a complete suite of policies in place which include Speaking Up policy, Code of Ethics, Equal Opportunities policy, Diversity policy and Recruitment policy, all of which deal with the anti-slavery initiatives either directly or indirectly. We also have a Corporate Social Responsibility policy. References to modern slavery and human trafficking are clear in all these policies. The overall responsibility for the policies lies with the HR Partner.

• Speaking Up policy

MHA encourages all its workers, customers and other business partners to speak up with concerns related to our its activities and supply chains. This includes any circumstances that may give rise to risk of slavery or human trafficking. The procedure set out in the Speaking Up policy is designed to make it easy for workers to make disclosures, without fear of retaliation. MHA launched a Whistle Blowing confidential hotline for staff in 2022. MHA also has in place an open and transparent grievance process for all employees including agency workers and Partners.

• Code of Ethics

MHA’s Code of Ethics makes clear to employees the actions and behaviour expected of them when representing MHA. We strive to maintain the highest standards of employee conduct and ethical behaviour at all times including when operating abroad and managing our supply chains.

• Equal Opportunities and Diversity policies

MHA is committed to providing equal opportunities in employment and to abolishing discrimination in employment and against customers. All employees go through our equality and diversity training. We are also fully committed to the elimination of unlawful and unfair discrimination and value the differences that a diverse workforce brings to the organisation.

• Recruitment policy

MHA uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

• Corporate Social Responsibility policy

MHA’s Corporate Social Responsibility policy was launched in 2022. This sets out the core principles and guidelines for MHA’s social responsibility activities and allows colleagues paid time to get involved in activities and work in their local community.

Training

MHA has a Modern Slavery course in its online Induction Core Policies programme which all new employees are required to complete within the first week of employment alongside Health and Safety training. Equality and Diversity training is carried out as part of MHA’s Representing Us course. MHA also continues to use the Core Policies Learning Pathway on the MHA Hub. All colleagues, regardless of length of service, have the Modern Slavery course on their dashboard. In addition, there is an annual compliance period. Reports are run to check that colleagues are completing these courses, and this is done on a monthly basis. The training includes assessments to measure awareness of modern slavery so that MHA is not simply measuring how many people have undertaken the training.

Awareness-raising programme

In light of the Modern Slavery Act, we assessed the awareness of these issues across our business and among our employees and clients. As well as training our employees, including temporary workers and Partners, MHA continues to raise awareness of modern slavery issues by addressing the below issues via MHA’s Core Policies Learning Pathway:

• the basic principles of the Modern Slavery Act 2015;
• how employers can identify and prevent slavery and human trafficking;
• what colleagues can do to flag up potential slavery or human trafficking issues to the relevant parties within MHA; and
• what external help is available.

This is being repeated at regular intervals.

Key Performance Indicators

All suppliers not working through FISCO required to provide either their own Modern Slavery Statement or complete a Modern Slavery Assessment. Right to Work in the UK checks are conducted for all new employees. Temporary workers from agencies are thoroughly checked prior to appointment. All new employees to complete Modern Slavery and Equality and Diversity training within the first week of employment. All employees to undertake Modern Slavery awareness training on an annual basis.

Board approval

This statement has been approved by the Management Board, who will review and update it annually.

Rakesh Shaunak 
10 January 2023