EY Modern Slavery Statement 2023

Executive summary

This Modern Slavery Statement sets out the actions taken by Ernst & Young LLP and its UK affiliates (‘EY UK1’or ‘the firm’) during our financial year from 2 July 2022 to 30 June 2023 (‘FY23’) to prevent modern slavery occurring within our operations or supply chains and has been prepared in accordance with section 54(1) of the Modern Slavery Act 2015. This is our eighth annual Modern Slavery Statement. 

No instances of modern slavery have been identified in our operations or supply chains during FY23.   

We have made further progress with our anti-modern slavery initiatives this year and have met the key aims for FY23 that were set out in our 2022 Modern Slavery Statement, as follows: 

1. Providing further training to higher-risk and higher-spend suppliers on human rights and modern slavery risks, and the standards required under our Supplier Code of Conduct. 
   
   
2. Expanding our supplier due diligence checks and monitoring our suppliers’ progress where areas for improvement were identified in our FY22 supplier assessment exercise. 
   
   
3. Reviewing our purchasing practices to ensure that we are not putting undue pressure on suppliers that may increase the risk of human rights issues.
   
   
4. Publishing and promoting our new Modern Slavery Policy and Response Plan within our business and carrying-out an expanded training programme for key teams who are responsible for implementing measures to identify or mitigate modern slavery occurring. 
   
   
5. Taking steps to embed human rights risk factors into our client acceptance process, including releasing a new UK Client & Engagement Acceptance Addendum policy to our existing Global policy, which put a mandatory requirement on our people to perform additional research on all clients, including adverse environmental, social and governance (ESG) media outcomes. 

We have set key aims for FY24 to ensure that our anti-modern slavery initiatives continue to progress and we have taken further steps to identify and address modern slavery risks within our operations or supply chains. 

Our purpose is building a better working world. Our anti-modern slavery initiatives are part of our wider corporate social responsibility and sustainability goals that help achieve this purpose. In accordance with the EY Global Human Rights Statement, we will not tolerate any form of human rights abuse within our business or supply chains. We are a signatory to and a participant member of the UN Global Compact, which aims to align worldwide business strategies and operations with universal principles on human rights, labour, environment and anti-corruption and we continue our pledge to support its principles. Further information about our approach on modern slavery and our wider initiatives is set out below. 

About us

Ernst & Young LLP is a limited liability partnership incorporated in England and is the parent organisation of the entities which make up EY UK. Ernst & Young LLP is a member firm of Ernst & Young Global Limited, a company limited by guarantee incorporated in England. 

EY UK is a leading professional services firm in assurance, tax, strategy and transaction and consulting services. All the companies which make up EY UK comply with the same standards and policies. 

As of the end of FY23, EY UK had 763 equity partners and 19,503 employees operating in 28 offices within the United Kingdom and Channel Islands.   

EY UK is a member firm of the global EY Network, which has member firms in more than 150 countries which share our commitment to building a better working world. 

Our progress

In our 2022 Modern Slavery Statement, we set out five key aims to be completed in FY23. These aims helped ensure that we are enhancing awareness of modern slavery risks and compliance with our policies and standards within our own business, and to ensure that we are carrying out ESG specific due diligence within our supply chains and driving supplier compliance with our standards. 

We successfully met the key aims set out in our 2022 statement, as follows: 

Details of our key aims and initiatives for FY24 are set out below. 

Our operations

The EY UK business operates in the professional services sector, and this is not deemed to be a higher-risk industry for modern slavery practices. Nevertheless, we are mindful of the potential for modern slavery to occur within our operations, and the need to implement robust measures to identify and mitigate against this risk. 

Policies and compliance

Our Global Code of Conduct (‘Code’) applies to all EY personnel across the globe and sets out the basis of our culture of acting ethically and in accordance with the highest professional standards. The Code makes it clear that all our people have a duty to take the most ethical course of action in any given situation and to report any behaviour which is inconsistent with the principles set out in the Code. All EY personnel are required to sign an annual declaration to confirm that they have read, understood and are in full compliance with the Code. 

Our UK Modern Slavery Policy applies to all EY personnel in the UK and has been revised this year. The policy sets out guidance as to what modern slavery is, how to spot and report potential instances of it and explains how our people are required to take individual responsibility for implementing our anti-modern slavery controls by: 

• Reporting any suspected instances of modern slavery. 
  
  
• Adhering to the relevant procurement procedures when procuring goods or services from external suppliers. 
  
  
• Ensuring that our client and engagement acceptance measures relating to ESG are followed when considering new client relationships or engagements. 
  
  
• Following our policies in relation to the recruitment and treatment of employees and contractors. 

We also published our Modern Slavery Response Plan this year, which sets out how the firm will handle any reported concerns of Modern Slavery. This defines the investigation process that the firm will follow, the further escalation and reporting measures that apply, and guidance as to potential remedial actions to help ensure the safety of potential victims of modern slavery. 

The firm’s Safeguarding and Prevent Policy sets out guidance as to how our people can help ensure that minors and vulnerable individuals are protected from harm or abuse, which includes how to recognise and report potential instances of, amongst other things, Modern Slavery. 

These policies are accessible via our intranet and our Global Code of Conduct. Any failure to comply with these policies is taken very seriously and can result in disciplinary action against our people up to and including summary termination. For EY personnel who are regulated professionals or members of professional bodies, a breach will also often result in a report being made to the relevant body. 

Training and awareness

We marked Anti-Slavery Day on 18 October 2022 by sending a communication to our people, which included links to our Modern Slavery Policy and details of how to raise queries or concerns about modern slavery to the firm. We also placed posters in all our UK offices to remind employees of their role in tackling modern slavery, which included QR codes linking to our Modern Slavery Policy and details of how to report concerns. 

We also have a learning module called “Safeguarding People at EY”, which is available via our online training portal and includes information about modern slavery and how to report concerns. 

We provided in-depth training to teams who are more likely to observe the potential indicators of modern slavery or who are responsible for implementing measures to identify or mitigate modern slavery risks. In FY23, we provided refresher modern slavery training to our GCO5 and SCS6 teams and extended the FY22 targeted Recruitment team training to our entire Talent7 team. We also piloted a modern slavery training module for client-facing employees in our Assurance service line, recognising the unique role accountants and auditors play in identifying potential indicators of modern slavery through their client work.

Reporting concerns

Our Modern Slavery Policy, Modern Slavery Response Plan and Safeguarding Policy each contain guidance on how to report any concerns that our people may have about modern slavery. There are various methods that our people can use to raise concerns, including: 

• By emailing our dedicated modern slavery mailbox, which is monitored by our GCO team. 
  
  
• By contacting our Help HR mailbox, helpline or chat messaging facility. 
  
  
• By contacting an appropriate manager. 
  
  
• By using our Ethics Hotline. 
  
  
• By using Culture Shift, our internal helpline for raising cultural concerns.

Our Ethics Hotline is operated by NAVEX Global, an independent external organisation which provides details of each report to the firm’s General Counsel, ensuring that each report is reviewed at appropriate levels within the firm, with each case then being investigated by suitably experienced individuals with support from our Talent, Risk or GCO team. Reporters have the option to remain anonymous and can provide information and evidence about their concerns via NAVEX Global’s portal if they are concerned about revealing their identity to the investigation team.

Our Ethics Hotline is available to the general public and details of how to make reports are set out prominently on our website, so anyone who has concerns about modern slavery or any other ethical matters relating to EY’s operations, our people or suppliers can raise them with us directly.

During FY23, no complaints or concerns were raised about modern slavery or human trafficking to the firm.

How we address key risks within our operation

We set high standards for ourselves and take positive action to ensure that modern slavery does not take place in our business. As a professional services firm, we are lower risk than some organisations but we remain vigilant to potential risks. We have identified the potential areas where risk might arise in our internal operations and taken steps to minimise that risk to the best of our ability, in line with our Code and values. 

• Pay structures - We have robust pay structures in place and are accredited by the Living Wage Foundation as a Living Wage employer. All our employees in the UK are paid at least at the level of the real Living Wage, and we require employees of our suppliers, who provide on-site services in our UK offices to also be paid the real Living Wage. 
  
  
• Recruitment - All employees joining EY UK are subject to robust onboarding checks including identity checks, reference checks, right to work checks, criminal record checks, and where applicable, education and professional qualification checks.

These checks help our Recruitment team to identify any potential red flags for possible modern slavery, and any discrepancies or irregularities will be followed up.

We use a specialist independent screening adviser to carry out these checks, and our Talent recruitment team work closely with our GCO and Risk Management8 teams to help ensure our pre-onboarding checks are relevant, fit-for-purpose, and industry-standard or above.  

Whilst there have not been any instances or suspicions of modern slavery identified or raised, in the event such concerns were raised, we have a comprehensive framework in place to investigate and ensure appropriate action will be taken.

• Acquisition due diligence - Our Risk Management and Talent teams carry out enhanced due diligence in respect of any entity that the firm is targeting for acquisition. This assessment includes a review of any modern slavery risks in respect of new personnel joining our firm as a result of the acquisition but also extends to identifying risks within the target’s suppliers and business relationships.  
  
  
• Encouraging people to speak up - We encourage people to raise any concerns about potential breaches of our Code of Conduct or values, or any other ethical matters, to anybody within the organisation – and they can feel confident that this will be taken seriously and with due sensitivity. This encouragement comes from regular communications from senior leaders, as well as focussed training to our people.  

Our supply chain

Our supply chain covers a wide range of products and services procured from third-party suppliers, which fall into the following general categories and are under the management of our SCS team:   

• Procurement services, which has two principal supply categories: 
  • Technology sourcing, which concerns the procurement of application and infrastructure software, professional and managed services, application development, hardware, telecommunications and external content, offering specialised sourcing solutions for Client Technology, Enterprise Technology, Information Security, Global Innovations, External Data, Regional Liaison Leads, and Business Enablement. 
    
    
  • Talent and BMC procurement which manages sourcing activities related to Automotive, Health and Insurance, Human Capital (spanning recruitment and external workforce), Learning and Development, Employee Rewards and Benefits, as well as Brand, Marketing and Communication, including Media Buying, Digital Marketing and Public Relations. 
• Real estate and workplace services which provides services such as planning, transaction management, design and construction, workplace standards, workplace procurement (e.g., facilities management, furniture and office furnishings) and lease/sublease administration (e.g., rent payments and sublease collections). 
  
  
• Travel, meetings and events services which supports the mobility of our people, enabling engagement with our clients and internal teams, and enhancing the culture and shared values whilst minimising the organisation’s total travel costs. 

In FY23, our annual UK spend with external suppliers under the management of our SCS team was approximately £372,000,000 with just over 2,300 suppliers.

Our procurement strategies for each of these areas are focussed on working with long term, strategic partners who share our commitment to socially and environmentally sustainable procurement, which includes checks to help ensure that modern slavery plays no part in their business. We employ a number of different initiatives to ensure that suppliers meet our standards, which are summarised below.

Our operational service lines also procure some services directly from third-party suppliers, including area-specific legal services, professional services, insurances and regulatory expenses. These suppliers are not under the management of our SCS team, but are managed via our procurement system and are subject to the supplier assessment measures set out below. 

Assessment of suppliers

We carry out ESG-specific due diligence prior to engaging with suppliers and require all potential suppliers to complete a core set of Request for Proposal (RFP) questions and provide appropriate evidence in relation to the ESG (including human rights and modern slavery) risks within their business and supply chain, the due diligence that they have carried out in relation to their vendors and the measures and safeguards which they have in place to prevent modern slavery occurring.   

Our sourcing managers also make use of our Sustainable Sourcing Framework to understand the potential ESG risks associated for particular products and services and the framework contains additional specific RFP questions to be asked to help assess the suitability of the supplier, particularly where the product or service sits within a higher-risk area for ESG issues (including modern slavery). This process helps us to make even better-informed decisions about the supplier that is chosen for the sourcing project. 

Our ESGES team provide sourcing managers with an RFP template and scoring guidance to assess the potential supplier’s compliance with our anti-slavery, sustainability and supplier diversity targets and strategies. This is intended to help differentiate suppliers with higher ESG standard and scoring includes a higher weighting for particular questions, such as how the supplier will help EY achieve our environmental and social goals. 

We have also introduced an enhanced assessment programme in relation to our existing suppliers who operate in areas which we consider to have identified as potentially being Higher Risk or High Spend. 

In FY22, we utilised the EY ESG Risk Assessment Tool (a proprietary tool offered by our CCaSS team to EY clients to assess the likely ESG risk types and risk levels of suppliers) to help shortlist suppliers who participated in the ESG Assessment Pilot. This pilot focussed on suppliers who operate in higher-risk areas or who have high-spend with us. In FY23, we have worked with the suppliers involved in the pilot to communicate feedback about their scores and areas requiring improvement and monitored their progress. 80% of the suppliers involved in the ESG Assessment Pilot received feedback on areas that required improvement and we have integrated the specific requirements into our contract management tool and ensured that these are picked-up with suppliers during their quarterly business review meetings to monitor progress and ensure that suppliers are acting on feedback given. No instances of modern slavery were detected during the pilot. 

Following the successful ESG Assessment Pilot, we will be expanding the enhanced assessment programme to a wider group of higher-risk suppliers in FY24, targeting further suppliers which operate in higher-risk areas or who have high-spend.

Higher-risk areas in our supply chain

Some of our suppliers operate in industries where there is an increased risk exposure for modern slavery. Our Risk Management team conducted a modern slavery risk assessment of our supply chain during FY23 and identified the following as the higher-risk areas for the firm:

Technology hardware

EY engages large international technology companies to source a range of technology hardware items including laptops, monitors and peripherals. These goods can be manufactured in developing countries, where modern slavery regulation is immature or lacking. Many of these products are procured through our Global entities but are consumed by our personnel. 

Our SCS team managing our procurement responsibilities have developed the EY ESG Sourcing Standards Framework which provides practical guidance on human rights considerations to the procurement staff involved in making sourcing decisions and reviewing supplier performance for this sector. 

We require our suppliers to provide assurance about their own supplier due diligence efforts and human rights practices. The Supplier Code of Conduct mandates a sub-contracting clause which requires suppliers to confirm that they take necessary steps to maintain visibility over labour rights risks within its entire operation and require subcontractors to comply fully with local laws (including labour law). In FY23, the EY Human Rights Training programme run by our Global Supplier Chain Services team was extended to our supplier base, which reinforced our human rights and social sustainability clauses emphasising on the labour standards expected. 

Onsite cleaning services and maintenance

This involves onsite cleaning, maintenance, physical security and other facilities related services provided around the various EY UK office premises. These services are largely provided to us by a selected group of suppliers who are managed by our Workplace Services team, a dedicated team within SCS which manages all workplace facilities services.   

In these areas, EY is indirectly exposed to potential risk of modern slavery through the recruitment and provision of people by our selected suppliers to carry out these services. The service providers in these sectors, or the sub-contracted labour recruiters further down their supply chain, could find themselves exposed to potential modern slavery risks if targeted by traffickers and gangmasters offering labour.

We use robust contractual rights (including an obligation for our supplier to perform various background checks on all recruits supplying services to us), regular governance and management discussions with the supplier, as well as rights to audit the supplier at our request to manage the associated modern slavery risks in the supply of services from these sectors. Further we require the supplier to pay the Living Wage to all of its people involved in the supply of services to us, monitor their working hours and require that they are not engaged using zero-hours contracts. The sourcing managers responsible for the suppliers in this area are equipped with the EY ESG Sourcing Standards Framework, which mandates modern slavery risks to be used as a key consideration during their collaboration with the suppliers. We also mandate the suppliers to adhere to EY policies and our Supplier Code of Conduct.  

Food catering and hospitality

This includes food service and preparation through external and in house catering, external meals and entertainment, venue hire and usage, and travel accommodation usage. These services are largely facilitated to EY UK by a selected group of suppliers and outsourced providers who are ethically aligned with EY values.

Many of our offices contain supplier managed in-house restaurants. Catering staff are recruited directly by our catering supplier. Our people in the course of their employment or membership of EY UK will use hotels and entertainment venues, all of which are booked through our travel and entertainment booking partners and suppliers. Common targets of exploiters in the food service and preparation industry include irregular migrants, those with financial difficulties, learning disabilities or minors working in the sector. Victims can often be subject to debt bondage, non-payment of National Minimum Wage or withheld wages, long working hours and concerns for workers' health and safety are also common. In the travel and hospitality sector it is common for providers to use agency employees and may not have complete visibility over their personnel’s terms of employment.   

Within our Supply Chain Services function there are various specialist teams such as the Workplace Services team and the Travel, Meetings & Event team who ensure there are sufficient controls in our supply chain processes to manage exposure to such areas. They oversee EY’s engagements in this sector and ensure adequate contractual obligations are in place with this category of suppliers and providers. As per the EY ESG Sourcing Standards Framework, sourcing managers in these areas are specifically required to consider modern slavery and labour risks during the end-to-end procurement process. 

Supplier governance and compliance

Our governance and compliance framework for suppliers is set out in our Global Procurement Policy, which contains the codes and policies that govern supplier engagement and the minimum requirements and prohibitions that apply within our supply chain. 

A key policy within this framework is our Supplier Code of Conduct ('Supplier Code') (pdf 162K), which is publicly available on our website and sets out clear standards of business conduct and ethics that we require our suppliers to adhere to. Our suppliers are required to comply with the Supplier Code, which is incorporated into our terms with the supplier. Exceptions will only be made if the supplier can evidence that they meet or exceed the standards outlined in the standards outlined in the Supplier Code.

The Supplier Code also sets clear of our suppliers in relation to human rights and social sustainability, including health and safety, working hours, working conditions and paying fair compensation. The Supplier Code requires that all employment within our supply chain should be freely chosen by the worker and there should be no use of bonded labour in or child labour in any form. We also make it clear that our suppliers are expected to pro-actively review and monitor risks of modern slavery in their own supply chain. Our recruitment agencies and brokers are required to carry out appropriate due diligence and ongoing management to ensure that the risk of worker exploitation is mitigated. 

To ensure that we can respond decisively to any failure to adhere to our standards, our supplier terms include the right to immediately terminate the supplier relationship where the supplier has committed a material breach of the code or any applicable law, including the Modern Slavery Act or any relevant labour law.

To help ensure that suppliers are mindful of modern slavery issues and understand our requirements, our ESGES Lead and CCaSS team delivered training sessions to the suppliers involved in our ESG Assessment Pilot during FY23. The training covered the topics of what human rights and modern slavery are, signs of modern slavery to look for, the relevance of legislation, and what the EY requirements on this topic are for our suppliers.

Human rights and anti-modern slavery are a key component of our ESG in supply chain strategy and this is reported on to the EY Chief Supply Chain Officer and Global CEO.  

Our next steps

To ensure that we continue to assess and develop our anti-modern slavery strategy and measures, we have the following key aims for FY24: 

1. Expand our internal Modern Slavery Training programme and provide targeted training to further areas of our client-facing business. 
   
   
2. Further develop our Modern Slavery Risk Assessment and Key Risk Indicators to facilitate enhanced insights and reporting on modern slavery hotspots, issues and initiatives, to reach senior leadership across the firm.  
   
   
3. Prepare and launch a dedicated modern slavery area on our intranet, to ensure that all of our anti-modern slavery tools, resources and information are easily accessible to our people and to help raise further awareness of modern slavery issues within our business. 
   
   
4. The ESGES team will be expanding our in-depth ESG assessments to a wider proportion of our suppliers who we have assessed as being in Higher-Risk or High-Spend areas and will continue to work with suppliers from previous assessments and monitor their progress against areas identified for improvement. 

Responsibility and compliance

The firm’s Board has overall responsibility for our modern slavery policy and for ensuring that all those under the firm’s control comply with it. Our General Counsel has responsibility for the production of our annual Modern Slavery Statement. Our UK&I Risk Management Leader has primary and day-to-day responsibility for implementing our modern slavery policy, monitoring its use and effectiveness, dealing with any queries about it and ensuring the firm’s internal control systems and internal auditing procedures are effective in countering modern slavery and human trafficking within our business and supply chain. 

The firm remains committed to improving its practices to combat modern slavery and human trafficking. 

Lisa Cameron | General Counsel and Designated Member for and on behalf of Ernst & Young LLP
12 December 2023

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