Modern slavery statement

Introduction and outline

We recognise that slavery and human trafficking (modern slavery) is a serious issue.  We are committed to acting ethically in all of our business relationships.

This statement is published in accordance with section 54(1) of the Modern Slavery Act 2015. It sets out the policies and procedures we have in place to minimise the risk of modern slavery or human trafficking occurring within our business or  in our supply chain.

Price Bailey is a top 40 UK accountancy practice specialising in providing audit, accountancy, tax and business advice to enable the growth of regional, national and international businesses We have 11 offices in the UK, an office in Dubai and a presence in St Lucia. We employ over 450 professionals and have a group turnover of over £40million.

We are a leading provider of professional services including accounting, audit, corporate finance, employment law, HR, structuring, insolvency, tax, and valuation work.

Treating people fairly is important to us and are the reason we are successful and differentiate ourselves in the market. We are fair and ethical in all dealings with the people with whom we have contact – our colleagues, our clients, our contacts, and our suppliers this is articulated through our core values and ethics. Our staff are highly trained, and many are qualified members of professional bodies. Several of the services we provide are highly regulated.

Our suppliers can include training providers, IT services (including software, security and storage providers), office equipment suppliers, hospitality and event companies, professional advisers, professional bodies, professional indemnity insurers, marketing, advertising, travel providers, facilities.

We have assessed the risk of slavery or human trafficking occurring in our own business as low.

Our policies relevant to modern slavery and human trafficking.

We conduct business predominantly in the UK, a lower risk jurisdiction where slavery and human trafficking is prohibited and criminalised by law.

We also provide professional services which is considered to be a lower risk sector but nonetheless we are alive to the threats of slavery and human trafficking occurring.

Our robust recruitment procedures include identity checks and require confirmation of the right to work in the UK, reference checks and fit and proper confirmations, all prior to commencing employment. Our preferred recruitment agencies have all been subject to due-diligence to ensure that they are aligned ethically.

All employees have signed contracts. We provide fair remuneration and flexible benefits.

Price Bailey has been recognised by the Best Companies survey 2023 as one of the best places to work in the UK.

We have in place the following policies that are relevant to our efforts to prevent modern slavery:

WELLBEING:- Our Stress and Mental Wellbeing at work policy sets out the measures Price Bailey has in place to support mental wellbeing and our trained Wellbeing and Mental Health ambassadors, to support individuals with ongoing wellbeing or mental health concerns. Our employees have access to two assistance programmes which offer a confidential help line and online resources supporting physical health, mental health, nutrition and mobility. We have an extensive wellbeing toolkit which offers tips and advice on effectively managing wellbeing and work life balance and provides legal advice.

Our Smart Working policy is designed to give our people more flexibility, help support the changing demographic needs of our teams and to promote wellbeing.

ECONOMIC CRIME:- We do not tolerate any involvement in money laundering, including bribery and the criminal facilitation of tax evasion when dealing with our own or our client’s affairs. All partners, employees and any sub-contractors used by us are therefore required to comply with the code of ethics of the Institute of Chartered Accountants in England and Wales including Professional Conduct in Relation to Taxation. Our position regarding aggressive tax schemes is made clear in our standard terms of engagement. We operate rigorous risk assessment and client due diligence procedures, being mindful of modern slavery as a predicate offence.

Price Bailey is committed to the highest standards of ethical conduct and integrity in its business activities in the UK and overseas. Senior management is committed to implementing effective measures to prevent, monitor and eliminate bribery.

SAFEGUARDING:- Price Bailey is committed to ensuring the safety of everyone involved in the firm’s activities. This includes the duty of care to safeguard children, young people and vulnerable adults during any interaction with Price Bailey, irrespective of duration or location.

WHISTLEBLOWING:- This policy covers all employees, officers, consultants, contractors, volunteers, interns, casual workers and agency workers. We are committed to conducting our business with honesty and integrity and we expect all staff to maintain high standards. Any suspected wrongdoing should be reported as soon as possible.

EQUALITY AND DIVERSITY:- Price Bailey is committed to encouraging diversity in our workforce and to ensuring that everyone is treated fairly.

Our aim is to develop and maintain a work environment where everyone is treated fairly and consistently. We work within the spirit and the practice of the Equality Act 2010 by promoting a culture of respect and actively challenging discrimination, should it ever arise. If we identify any obstacles to opportunities for training and development, we seek to remove these as far as we can, to ensure that no one is unfairly disadvantaged.

There have not been any reported incidents of slavery or trafficking during the year.

Due diligence processes undertaken in relation to slavery and human trafficking in the business and supply chains;

We conduct business predominantly in the UK, a lower risk jurisdiction where slavery and human trafficking is prohibited and criminalised by law.

We undertake due diligence on our main suppliers, and we only work with suppliers who we believe to be reputable, many of which we have a long-standing relationship with which is based on mutual trust.

We have a significant degree of confidence that the risk of modern slavery occurring in our supply chain remains low.  We will be enhancing our due-diligence procedures over the next 12 months.

Risk assessment and management;

We have not found, or been made aware of, any instances of modern slavery or human trafficking in our business or supply chain.

Our economic crime risk assessment framework and customer due diligence procedures allow us to address and mitigate the risks associated with many of the offences for which modern slavery is a predicate or connected offence. As well as avoid the unwitting involvement of Price Bailey LLP in any of the above activity.

Assessment of effectiveness and performance indicators

Professional capacity is one of our key performance indicators and this measure, along with our regular employee surveys, is a key pressure gauge in the monitoring of our wellbeing agenda.

Our standard payroll terms require clients to confirm responsibility for completing the checks in accordance with the Government’s Code of Practice “Preventing Illegal Working,” and the Immigration, Asylum and Nationality Act 2006.

These terms also require confirmation that workers are paid at least the National Minimum Wage or National Living Wage (depending on which applies).

We provide regular CPD training to ensure our teams are up to date with the latest development. The programme this year included economic crime and transparency.

We record and respond to any concerns or incidents raised by clients or internally.

Staff training

This statement is shared with our all our people.

All new joiners will receive this statement as part of their firm induction. Key policies as outlined above are also included and explained during this process.

Internal guidance on Modern Slavery is in place and all staff receive mandatory economic crime training.

In the last year all staff have been required to watch a training film produced by our professional body (in conjunction with HMRC) that highlights the risks, warning signs and human impact of modern slavery.

Going forward

We will be developing a separate policy addressing specifically slavery and human trafficking separately, to continue to raise awareness amongst our teams and review and improve  our procurement due-diligence.

We will continue to assess modern slavery or human trafficking occurring within our business and in our supply chains, and respond where appropriate.

A further statement will be published in 2025.