Slavery and Human Trafficking Statement 2020
Introduction
This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes our modern slavery and human trafficking statement for the financial year ending 31 May 2020 for Johnston Carmichael LLP and all group entities.
Organisation Structure
Johnston Carmichael LLP is a Limited Liability Partnership registered in Scotland (SO303232) providing accountancy and business advisory services to clients, primarily based in Scotland but also elsewhere in the United Kingdom. The firm has premises in Aberdeen, Dundee, Edinburgh, Elgin, Fraserburgh, Forfar, Glasgow, Huntly, Inverness, Inverurie, London, Perth and Stirling. We have 63 Partners, 730 staff and a turnover of over £51.4M for the financial year ending 31 May 2020 across the Johnston Carmichael group entities.
Supply Chains
We are committed to ensuring our supply chain is free from any form of slavery or human trafficking. As we operate in the professional services industry, our supply chain is centred around the purchasing of goods and services that support the functioning of our offices and provision of services to our clients; including the referral of accountancy work to other firms, several of whom are within the international accountancy network, PKF. Consumables purchased include office supplies, marketing materials, IT equipment and estate services such as cleaning, waste management, office fixtures and fittings, security, uniforms and catering.
Johnston Carmichael believes in giving back to the communities in which we operate and supporting local businesses. Many of our suppliers are local (Scottish) businesses who have their own due diligence in place to ensure they procure services and/or materials from socially responsible organisations. As we operate geographically within the UK, and our supply chain is predominantly UK based, our verification of supply chains includes fair treatment and pay of workers and verification of the right to work in the UK.
Due Diligence, Risk Evaluation and Management
Since the inception of the obligations to report on measures to ensure that all parts of our business and supply chain are slavery free, we have written to all our suppliers, requesting they verify the steps they take to ensure their own supply chain is free from slavery or human trafficking. We continue to implement and enforce effective systems and ongoing controls with new and existing suppliers. We will investigate any potential risk areas and take action (including termination) as appropriate. We have also updated our tender process to include the same verification processes as part of our standard due diligence practices.
As a result of the Coronavirus pandemic, we remain mindful that it is critical to continue to identify and address risks of modern slavery in our operations and supply chains. Our focus internally is primarily on the health and safety of our own staff and we have implemented a variety of actions to prevent the spread of the virus, including the adoption of tailored workplace guidance, adopting physical distancing measures and paying Company sick pay to those who are self-isolating and cannot work. Whilst recruitment activity has been limited during this period, we have adapted processes to ensure that rigorous checks are maintained during any virtual interview and recruitment processes.
We continue to maintain proactive engagement with external suppliers, mindful of the impact of late cancellations. We are acutely aware of the potential that vulnerable workers can be exploited by third parties seeking to profit from heightened demand and this analysis has been considered in our approach to the procurement of PPE materials for both our staff and our office estate.
Training Resources and Policies
As a firm we aspire to be recognised as a responsible corporate citizen in all our relationships. We have a range of responsible business policies that outline our approach, and we expect all employees to conduct business relationships with honesty and integrity. Our whistleblowing policy also sets out a process for reporting any concerns about wrongdoing or breaches of policies which includes reporting on forced or compulsory labour or human trafficking.
Investment in our people is a critical strand in achieving responsible corporate citizenship. To ensure a satisfactory level of understanding of the risks and signs of modern slavery and human trafficking in our supply chains and our business, we have created and made available e-learning resources to all of our staff including those involved in recruitment and procurement. We are also developing an internal program, JC Academy, covering both technical training and ethics and compliance elements, to ensure our staff have both the technical competencies and values-based skills development to empower them.
This statement has been approved by the Board of Johnston Carmichael LLP on behalf of its Members and all group entities and is signed by:
Andrew G Walker
Chief Executive
A review of this statement will next take place on 30 November 2021.
