PRICEWATERHOUSECOOPERS LLP modern slavery statement summary (2021)

Organisation address
1 Embankment Place,
London,
WC2N 6RH

We asked the organisation a series of questions about its modern slavery statement. Its answers are published on this page as a statement summary.

This statement provides information for all 6 recommended topics

What is a modern slavery statement?
UK law requires certain organisations to publish an annual modern slavery statement on their website, setting out the steps they are taking to address modern slavery risks in their operations and supply chains. Read more in the government guidance on publishing modern slavery statements.
Link to full statement
Go to full modern slavery statement on organisation’s website

PDF version of the statement (optional)

There is no PDF version of this statement.

PDF statements were first introduced to the registry for the 2023 statement year.

About this statement summary

All answers relate to the financial year covered by the statement. The organisation is responsible for all the information it provided. Some of our questions are optional, so organisations may not have answered all of them. The statement summary does not replace the full modern slavery statement – below we provide a link to the full statement on the organisation’s website.

Contents

Statement period and sign-off details

The statement covers the following period:
1 July 2020 to 30 June 2021

The statement was signed off by:
Kevin Ellis (Senior Partner and Chairman)

It was approved by the board (or equivalent management body) on:
6 December 2021

Recommended topics covered by the statement

Government guidance encourages organisations to cover a range of topics in their modern slavery statements, setting out the steps they’re taking to address modern slavery risks in their operations and supply chains. Read about the recommended topics in the statutory guidance.

We asked the organisation to tell us which topics its statement covers.

Topics recommended by government guidance Organisation’s response
The organisation’s structure, business and supply chains Covered
Policies Covered
Risk assessment Covered
Due diligence (steps to address risk) Covered
Training about modern slavery Covered
Goals and key performance indicators (KPIs) to measure the effectiveness of the organisation's actions and progress over time Covered

The organisation’s sectors and turnover

Sectors

The organisation operates in the following sectors:

  • Professional and administrative services and supplies, including legal, consulting and accounting services

Turnover

Its turnover in the financial accounting year of this statement was:

Over £500 million

If the organisation is a public body, this amount is based on the organisation’s budget for the year of the statement.
What does 'turnover' refer to in group statements?
If this is a group statement, this includes the total turnover for all the organisations covered by the statement.

Number of years producing statements

The organisation has been producing modern slavery statements for the following number of years:
More than 5 years
How does this work for group statements?
If the statement is for a group of organisations, this answer applies to the organisation with the longest history of producing statements.

Policies (optional)

We asked the organisation whether its policies include the following provisions in relation to its domestic and international supply chains, as well as its own operations.
Policy provisions we asked about Organisation’s response
Freedom of workers to terminate employment Included
Freedom of movement Included
Freedom of association Included
Prohibits any threat of violence, harassment and intimidation Included
Prohibits the use of worker-paid recruitment fees Not included
Prohibits compulsory overtime Included
Prohibits child labour Included
Prohibits discrimination Included
Prohibits confiscation of workers' original identification documents Included
Provides access to remedy, compensation and justice for victims of modern slavery Included
Other
Not included

Training (optional)

We asked the organisation whether it provided training on modern slavery, and who it was for.
What counts as training?
We explained that by ‘training’ we meant anything designed to increase knowledge and skills around identifying, addressing or preventing modern slavery risks. This could range from formal training courses to broader awareness-raising activities such as workshops or webinars.
We asked who the training was for Organisation’s response
Your whole organisation Yes
Your front line staff Yes
Human resources Yes
Executive-level staff Yes
Procurement staff Yes
Your suppliers Yes
The wider community No
Other
No

Monitoring working conditions (optional)

Engaging with others

We asked the organisation to tell us who it engaged with to help monitor working conditions across its operations and supply chains.
We asked who the organisation engaged with Organisation’s response
Your suppliers Yes
Trade unions or worker representative groups No
Civil society organisations No
Professional auditors Yes
Workers within your organisation Yes
Workers within your supply chain No
Central or local government Yes
Law enforcement, such as police, GLAA and other local labour market inspectorates No
Businesses in your industry or sector No

Social audits

We asked the organisation to tell us about any social audits it used to look for signs of modern slavery.
What are social audits?
A social audit is a review of an organisation’s working practices from the point of view of social responsibility, and should include an evaluation of working conditions in the organisation’s operations and supply chains. By their nature, audits of supplier workplaces represent a snapshot in time.
Social audits we asked about Organisation’s response
Audit conducted by your staff No
Third party audit arranged by your organisation No
Audit conducted by your supplier’s staff No
Third party audit arranged by your supplier Yes
Announced audit No
Unannounced audit No

Grievance mechanisms

We asked the organisation how workers in its operations or supply chains could raise concerns or make complaints.
We asked if workers could raise concerns this way Organisation’s response
Using anonymous whistleblowing services, such as a helpline or mobile phone app Yes
Through trade unions or other worker representative groups No

Other ways of monitoring working conditions

We asked the organisation whether it had any other ways of monitoring working conditions across its operations and supply chains:
We conduct extensive due diligence/supplier engagement. Our 'Speak Up' helpline is available to all employees and third parties to report any concerns, including suspected instances of modern slavery.

Modern slavery risks (optional)

Warning Identifying modern slavery risks is a vital step towards eradicating it. The government encourages organisations to be as open and transparent as possible, to improve understanding, collaboration and best practice around tackling this worldwide problem.
We asked the organisation to describe up to 3 priority risks it focused on during the period of the statement, including details of the affected workers, the activity involved, and the location.

Priority risks for this organisation (1 of 3)

Food - here there are risks relating to often migrant agricultural workers in highly manual harvesting and processing roles and the catering personnel staff in our offices (location: UK and Europe)
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Within your supply chains.
  • Tier 2 suppliers
    Provide products and services to your organisation via your Tier 1 suppliers.
  • Tier 3 suppliers and below
    Provide products and services to your organisation via your Tier 2 suppliers or the next higher level in the chain.
Who was it most likely to affect Organisation’s response:
  • Women
  • Migrants
In which country Organisation’s response:
  • Spain
  • United Kingdom
  • Italy
Actions or plans to address this risk Organisation’s response: We collaborate with our catering supplier to understand and manage the risks. Full-time catering staff working in our offices are recruited directly by our caterer. Temporary staff agencies used are audited on a biennial basis to check for compliance with UK legislation. In FY20 our caterer became a member of Sedex, an ethical trade body that ensures standardised and robust external audits with human rights in scope. Our caterer continues to extend Sedex membership throughout their supply base.

Priority risks for this organisation (2 of 3)

Information technology hardware - here the risks lie in the manufacture and assembly of devices we procure and in the extractive minerals further upstream in the supply chain (location: China)
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Within your supply chains.
  • Tier 2 suppliers
    Provide products and services to your organisation via your Tier 1 suppliers.
  • Tier 3 suppliers and below
    Provide products and services to your organisation via your Tier 2 suppliers or the next higher level in the chain.
Who was it most likely to affect Organisation’s response:
  • Women
  • Migrants
In which country Organisation’s response: China
Actions or plans to address this risk Organisation’s response: We work closely with our laptop supplier to increase supply chain transparency and strengthen assurance: we include safeguards in our commercial agreements, engage the supplier to understand the details of their risk management and conduct in-depth due diligence. Our supplier and manufacturing subsidiary - where our laptops are made - are RBA Validated Assessment Programme members and are audited as part of this. In FY22, we will track corrective actions and continue to engage our supplier.

Priority risks for this organisation (3 of 3)

Waste and recycling - here the risks relate to highly manual roles e.g. sorting at waste and recycling destinations. Victims are reported by GLAA to commonly be Eastern European males (location: UK).
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Within your supply chains.
  • Tier 2 suppliers
    Provide products and services to your organisation via your Tier 1 suppliers.
  • Tier 3 suppliers and below
    Provide products and services to your organisation via your Tier 2 suppliers or the next higher level in the chain.
Who was it most likely to affect Organisation’s response:
  • Migrants
In which country Organisation’s response: United Kingdom
Actions or plans to address this risk Organisation’s response: Our approach is to progressively conduct due diligence on high risk waste streams - those that are highly manual e.g. recycling sorting/processing - for all of our UK offices. This includes analysis of supplier disclosures, policy commitments, intelligence gathering and adverse media . In FY21, this was carried out for suppliers representing 28% of our UK waste mass. We plan to increase this figure year-on-year hereon. Where proper controls or an issue is identified, we engage the supplier.

Indicators of forced labour (optional)

We asked the organisation whether its statement refers to finding any International Labour Organization (ILO) indicators of forced labour.
What are ILO indicators of forced labour?
The International Labour Organization (ILO) has produced a list of the most common signs of forced labour. They’re based on the definition of forced labour as ‘all work or service which is extracted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.’ More details and guidance are available on the ILO website, and in their publication ILO indicators of forced labour
ILO indicators we asked about Organisation’s response
Abuse of vulnerability Yes
Deception No
Restriction of movement No
Isolation No
Physical and sexual violence No
Intimidation and threats No
Retention of identity documents No
Withholding of wages No
Debt bondage No
Abusive working and living conditions No
Excessive overtime No
Other
-

Actions taken in response to finding ILO indicators

We asked the organisation to tell us whether its statement refers to any actions it took after finding indicators of forced labour
Actions we asked about Organisation’s response
Financial remediation, including repayment of recruitment fees No
Change in policy No
Change in training No
Referring potential victims to government services No
Supporting victims via NGO No
Supporting investigations by relevant authorities No
Other
We have worked wtih our suppliers to reach satisfactory comfort over issues identified in tier 3 and 4.

Demonstrating progress (optional)

We asked the organisation how its statement demonstrates progress over time in addressing modern slavery risks. They provided the following answer:
We use several supply chain specific metrics that, along with progress against commitments, help inform the effectiveness of our programme.