Modern Slavery and Human Trafficking Statement

For the financial year ending 31 March 2025

This statement is made in accordance with Section 54(1) of the UK Modern Slavery Act 2015 and sets out the steps that the Shaw Gibbs Group (Shaw Gibbs), a large UK-based accountancy and advisory firm, is taking to prevent modern slavery and human trafficking within our operations and supply chains.

Modern slavery refers to the exploitation of individuals who cannot leave their current situation due to violence, abuse of power, coercion, or threats of violence. It is a clear violation of human rights, and comes in many forms:

Slavery – a person is treated as the property of another

Servitude – a person is forced to live and work under coercive conditions

Forced or compulsory labour – work provided against someone’s will, including withholding wages or physical confinement

Human trafficking – either within country or across borders.

Debt bondage – a person is forced to work to repay a debt that is impossible to repay

Child slavery – exploitation of children for marriage, criminal activity, labour

Domestic servitude – a person working in a private home under exploitative conditions

All forms of modern slavery are characterised by the inability of an individual to leave a situation freely due to control through various means, and are often hard to detect.

  1. Our business

Shaw Gibbs is a professional services firm providing accountancy, tax, audit, payroll, outsourcing and advisory services. We operate in the UK across multiple offices, with some offshore partnerships in Ghana, India and South Africa to support data processing and transactional services. We engage with a diverse range of suppliers and partners and are constantly working to ensuring that our supply chains have no connection to modern slavery and human trafficking.

  1. Our commitment

We are committed to upholding the highest standards of integrity and accountability and will not tolerate modern slavery or human trafficking in any form. This statement marks our ongoing efforts to identify and mitigate the risks of modern slavery across our operations, and reflects our commitment to continuous improvement.

  1. Our structure and supply chains

While the professional services sector generally presents a lower risk than other industries for direct involvement in modern slavery, we acknowledge that certain parts of our supply chain may present higher risks, particularly where third-party services are involved. Key high-risk areas include:

  • Facilities management and office services: Cleaning, catering, and security services are often outsourced and can carry risks of low-paid or migrant labour in poor conditions
  • IT hardware and equipment: Sourcing of electronic equipment and components may involve complex global supply chains where forced labour is a known issue, especially in regions such as Asia and Africa
  • Merchandise and branded goods: Promotional items and branded materials may be sourced from suppliers using offshore manufacturing, often with limited transparency
  • Recruitment and temporary staffing: Use of temporary, agency, or offshore contractors (e.g. for IT or administrative support) introduces risk, particularly if labour suppliers lack ethical controls
  • Professional services procurement: While lower risk, outsourced legal, transcription, or document review services (especially offshore) require oversight.

  1. Policies and procedures

To address these risks, we have implemented the following policies and frameworks:

  • Modern Slavery and Human Trafficking Policy – outlining our zero-tolerance approach and providing guidance for staff and procurement teams, ensuring that staff at all levels are aware of their responsibility to uphold human rights
  • Procurement and Supplier Code of Conduct – mandating ethical sourcing practices, including compliance with the Modern Slavery Act
  • Whistleblowing Policy – enabling staff, clients, and suppliers to report concerns confidentially and without fear of reprisal at modernslavery@shawgibbs.com

All relevant policies are reviewed annually by a multi-disciplinary team, including operations and procurement, IT, compliance, and the people and culture team. These policies are supported by mandatory training for all employees.

  1. Due diligence and risk assessment

We have begun a structured programme to identify and assess modern slavery risks across our supply chain. This involves:

  • Categorising suppliers by sector and geographical risk, using the Walk Free Global Slavery Index
  • Where applicable requiring suppliers, who we partner with in an ongoing capacity to have signed modern slavery compliance declarations
  • Introducing contractual clauses obligating suppliers to meet anti-slavery standards and permitting audits or assessments where needed.

  1. Effectiveness and next steps

We are committed to measuring the effectiveness of our approach through the following key performance indicators:

  • Percentage of high-risk suppliers reviewed or audited annually
  • Completion rate of mandatory training modules among employees
  • The number of reported concerns and outcomes via whistleblowing or other channels.

  1. Planned next steps in the next 12 months include:

  • Introducing training on modern slavery risks and internal policies, and incorporating this into employee onboarding processes. We aim to increase awareness through this training by 50% against baseline
  • Establishing a multi-disciplinary team with enhanced training in managing modern slavery and human trafficking risks, who are responsible for ongoing compliance and risk management
  • Reviewing our recruitment processes to ensure they mitigate modern slavery risks.

  1. Board approval

This statement has been approved by the Board of Directors of Shaw Gibbs on 5 January 2026 and will be reviewed and updated annually by the modern slavery team.

Signed

Peter O’Connell
CEO
5 January 2026