CROWE U.K. LLP modern slavery statement summary (2021)

Organisation address
2nd Floor, 55 Ludgate Hill,
London,
United Kingdom,
EC4M 7JW

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:
31 March 2020 to 30 March 2021

The statement was signed off by:
Nigel Bostock (Chief Executive)

It was approved by the board (or equivalent management body) on:
29 September 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:

£100 million to £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:
1 to 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 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
Crowe U.K. LLP's professional service supply chain consists, on the whole, of other regulated professional service firms and individuals. Its assessment is that this represents a very low risk of anyone supplying it with services being involved in slavery.

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 No
Your front line staff No
Human resources No
Executive-level staff No
Procurement staff No
Your suppliers No
The wider community No
Other
The firm has a Risk Manual, a policy document which applies to all partners and employees and makes specific reference to the MSA and the Firm's position on improper business conduct of any sort. Everybody confirms compliance with this yearly.

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 No
Workers within your organisation Yes
Workers within your supply chain Yes
Central or local government No
Law enforcement, such as police, GLAA and other local labour market inspectorates No
Businesses in your industry or sector Yes

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 Yes
Third party audit arranged by your supplier No
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:
Undertaken a review of our supply chain over an 18-month period to identify primary risk areas based on supplier activity types.

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)

The Home Office’s 2017 Typology of Modern Slavery Offences has been identified cleaning industry in particular as high-risk area for modern slavery and human trafficking.
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Within your supply chains.
  • Tier 1 suppliers
    Provide their products and services directly to your organisation.
Who was it most likely to affect Organisation’s response:
  • Women
  • Migrants
In which country Organisation’s response: No details provided
Actions or plans to address this risk Organisation’s response: From review of our suppliers, the cleaners are employed by our office providers. We have obtained MS statements in respect of our Property consultants.

Priority risks for this organisation (2 of 3)

we also looked at supply chain risk areas within events, transport and courier, and hotels.
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Within your supply chains.
  • Tier 1 suppliers
    Provide their products and services directly to your organisation.
Who was it most likely to affect Organisation’s response:
  • Migrants
In which country Organisation’s response: No details provided
Actions or plans to address this risk Organisation’s response: There were no external events held during the pandemic so it was not applicable for the period. For transport and courier services, there are limited examples of courier and Royal Mail delivery identified in the key word searches. There is to be a full analysis of firms utilised for these services during 2021/22.

Priority risks for this organisation (3 of 3)

Recruitment and use of agents
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Within your supply chains.
  • Tier 1 suppliers
    Provide their products and services directly to your organisation.
Who was it most likely to affect Organisation’s response:
  • We have selected England below, because we were forced to select at least one country. In reality, we did not identify particular risks emanating from one or more countries and it was not appropriate to specify particular countries. in response to the direct question.
In which country Organisation’s response: No details provided
Actions or plans to address this risk Organisation’s response: Considered low risk given our recruitment is through established agencies, although a number are below the MS reporting threshold (refer to next page). Our workforce are primarily skilled and within Crowe UK, recruited from within the UK.

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
Organisation’s response
The organisation told us its statement does not refer to finding any International Labour Organization (ILO) indicators of forced labour.

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 will review whether enhanced due diligence required for certain suppliers over a defined threshold. Look at recurring suppliers, notwithstanding that they are below the financial reporting threshold, to help them understand potential issues and generally embed good practice in our supply chain. If we determine there should be enhanced due diligence going forward, we will adapt policies, processes and training accordingly.