Modern Slavery Act 2015: Slavery and Human Trafficking Statement
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) and sets out the steps that FTI Consulting LLP (“FTI Consulting”) has taken during the financial year ending 31 December 2016 to ensure that slavery and human trafficking are not taking place in any part of FTI Consulting’s supply chains or business.
About FTI Consulting
FTI Consulting LLP is ultimately owned and controlled by FTI Consulting, Inc., a Maryland corporation listed on the New York Stock Exchange. FTI Consulting is a global business advisory firm dedicated to helping organisations manage change, mitigate risk and resolve disputes: financial, legal, operational, political & regulatory, reputational and transactional. The FTI Consulting group has more than 4,700 employees located in 29 countries. In the United Kingdom, FTI Consulting operates primarily through FTI Consulting LLP (a limited liability partnership in incorporated in England and Wales with company number OC372614).
Since its establishment, FTI Consulting has dedicated itself to providing its clients with market-leading management consulting advisory services, performed in accordance with the highest ethical standards. By consistently delivering sophisticated and innovative solutions to the challenging and complex issues that impact enterprise value, FTI Consulting has earned its reputation as a premier consulting firm. FTI Consulting’s institutional reputation relates directly to its individual commitment to professional responsibility, as well as to professional excellence. FTI Consulting’s continued status as a trusted and respected advisor to the business community and the law firms that serve it, as well as to institutions in the public sector, depends in large measure on its adherence to the highest standards of professionalism, independent judgment, expert advice and accountability. These bedrocks of FTI Consulting’s corporate culture are reflected in its corporate values:
I act with integrity
I am committed to continuous improvement
I am committed to quality and accountable for results
I welcome diversity and differences of opinion
I support others
The Act defines modern slavery as “slavery, servitude and forced or compulsory labour” as well as human trafficking. FTI Consulting uses the same definition of “modern slavery” in this statement.
As part of its commitment to the global community, FTI Consulting upholds individual human rights in all its operations. This means, in part, that FTI Consulting provides reasonable working hours and fair wages for those who work on its behalf. FTI Consulting opposes the use of modern slavery in all forms and has a zero-tolerance policy for the use of child or forced labour, or human trafficking practices, whether within its business or its supply chains. Further, FTI Consulting will not knowingly do business with sub-contractors, business partners or suppliers who violate these practices.
FTI Consulting is a signatory to the United Nations Global Compact (“UNGC”) and adopts and adheres to its principles. Principle one is “the protection of internationally proclaimed human rights”, principle four is “the elimination of all forms of forced and compulsory labour” and principle five is “the effective abolition of child labour”.
The principles of the UNGC are enshrined in FTI Consulting’s Code of Ethics and Business Conduct (the “Code of Conduct”), which also includes its policies on, among other things, equality and diversity, anti-corruption and whistleblowing). This policy provides other information about how FTI Consulting conducts its day-to-day activities. New FTI Consulting staff are provided training on the policy as part of their induction upon joining the firm. The standards set out in this policy are reflected in the firm’s other policies and procedures and FTI Consulting aims to enshrine them in whatever it and its employees do.
FTI Consulting also has a standalone whistleblowing policy which encourages employees to raise concerns of any improper conduct or violation of applicable laws or internal policies and procedures (including the Code of Conduct).
FTI Consulting’s employment and labour practices reinforce its approach to modern slavery. FTI Consulting has created a safe, healthy and inclusive workplace with a strong culture of collaboration and respect for others. This is underpinned by a number of policies relating to diversity, dignity and inclusiveness which reflect a business environment in which the firm’s ethical values are promoted.
FTI Consulting’s supply chain is extensive and includes a large number of suppliers providing a broad range of goods and services. In 2016, the top 10 suppliers accounted for nearly 36% of its total annual supplier spend (and with the top 20 suppliers accounting for nearly 45% of total annual supplier spend). These key suppliers are the businesses which help the firm to run its office premises (e.g. catering, utilities) or who supply the firm with the technology, infrastructure and other support needed to run its business and serve its clients (e.g. IT, telecoms, travel, recruitment, stationery, supplies and professional services). A number of these first-tier suppliers have been working with the firm for a number of years.
Risk assessment and due diligence
FTI Consulting’s suppliers vary both in nature of the services they provide as well as in the frequency with which FTI Consulting works with them - some are one-off or infrequent; others represent a substantial proportion of our annual supplier spend and/or are day-to-day suppliers.
As a professional services firm, FTI Consulting considers the risk of modern slavery existing within its business to be low. FTI Consulting considers there is arguably a greater risk of modern slavery within its supply chain (including suppliers of personnel, goods and services), although still considers the risk overall as low, given the nature of our business and the types of goods and services provided by our suppliers. FTI Consulting is committed to improving its practices and sets out below steps FTI Consulting has taken and proposes to take to investigate and ensure that modern slavery does not take place in any part of its business or supply chain:
- during 2017, taking a risk-based approach, FTI Consulting will be contacting certain suppliers (particularly first-tier suppliers and those suppliers who, by the nature of the goods and services they provide and/or the geographic location from which such goods and services are provided, at a higher risk of modern slavery) to ask that they formally set out the steps that they have taken to identify and manage the risk of modern slavery within their own business and supply chains and to confirm that they comply with the requirements of the Act;
- for new strategic supplier relationships FTI Consulting has started to introduce specific contractual obligations within the relevant supplier agreements designed to promote a proactive, compliant approach to modern slavery in such suppliers’ operations and supply chains. Breach of these obligations will entitle FTI Consulting to terminate the contract with immediate effect. In determining when such contractual provisions need to be included, FTI Consulting will consider a range of factors, including whether or not there are indications of a high risk of modern slavery (for example, the nature of the goods and services to be provided and/or the location from which they will be provided);
FTI Consulting will be updating the Code of Conduct itself (as well as the associated training on that code) to make more express reference to modern slavery; and
FTI Consulting will publish this statement internally in order to raise awareness within its workforce.
If FTI Consulting becomes aware of an incidence of modern slavery within its supply chain, FTI Consulting will work with the relevant supplier to implement swift remedial action (which may include termination of the underlying contract). In determining the appropriate remedial action, consideration will naturally be given to the action(s) which will deliver the safest and best outcome for the potential victims of modern slavery. FTI Consulting expects its suppliers to engage with FTI Consulting constructively and responsibly and to show their determination and willingness to rectify issues promptly and effectively.
Effectiveness and Performance Review
Given that FTI Consulting has assessed the risk of modern slavery occurring in its business and/or supply chain to be low, FTI Consulting does not have key performance indicators specifically in relation to modern slavery. Any instance of modern slavery would constitute non-compliance with, and a breach of, applicable employment laws, policies and practices and/or the Code of Conduct. FTI Consulting meets at least annually with a number of its key / first-tier suppliers (for example, catering, cleaning, mail/print room service providers) to discuss performance issues.
Training and awareness
Upon joining FTI Consulting, all staff are given training on the Code of Conduct, which makes clear the firm’s zero-tolerance policy for the use of modern slavery in FTI Consulting’s business and supply chain. As mentioned above, FTI Consulting will publish this statement internally in order to raise awareness.
This statement is made pursuant to section 54(1) of the Act and constitutes FTI Consulting LLP’s slavery and human trafficking statement for the financial year ended 31 December 2016.
This statement has been approved by the Managing Member of FTI Consulting LLP. Julia Sherlock, FTI Consulting’s EMEA Chief Operating Officer, has been authorised to sign this statement on behalf of FTI Consulting LLP.
Chief Operating Officer, EMEA
For and on behalf of FTI Consulting LLP
23 May 2017