Modern Slavery Statement 2022/2023
Modern slavery is a brutal and heinous crime. We recognise that all businesses must remain vigilant to ensure they are not unknowingly complicit in the abuse and exploitation of individuals for profit.
This statement outlines our firm's commitment to improving the detection and prevention of modern slavery in our business and supply chain and describes the progress we have made during the 12 months to April 2023.
Our areas of improvement in financial year 2022-23 include:
· Amending our founding legal document to reflect our core commitment to positive ESG impact
· Publishing our inaugural ESG Impact Report
· Setting global guidance for office cleaners to be paid a fair wage and to work in a healthy and inclusive environment.
We are a strategy consulting firm. We help clients tackle their most intricate challenges, from high-level corporate strategy to in-depth data analytics and everything in between.
Established in 1987, we now have offices around the world: London, New York, Boston, Milan, Paris, Rotterdam, Warsaw, Munich, Hong Kong, Shanghai, Sydney & Melbourne.
Across this diversity of work, countries and cultures, a shared purpose runs through our people: our commitment to the highest standards of ethical conduct and integrity in our activities globally.
A firm that endures can only do so if it is also a force for good and is worthy of the trust placed in it. Our Code of Conduct requires our people to consider the impact of their decisions on colleagues, clients, suppliers and the wider community and environment.
We consider modern slavery – in all its forms – to be an appalling breach of fundamental human rights. Our zero-tolerance approach to modern slavery is made clear in our Global Professional Standards Policy, which forms a contractual commitment made by our people.
We are committed to fostering an inclusive culture in which people of all backgrounds can thrive, with full expectations set out in our Equality, Diversity & Inclusion Policy. Our recruitment processes encourage applications from all, regardless of age, sexual orientation, gender identity or gender expression, transgender status, disability, marital status, pregnancy or maternity, religion or belief, race or ethnic origin, and socioeconomic background.
To support this, we only use specified, reputable employment agencies. We also have staff network groups to actively support the inclusion of all our colleagues in the firm and raise awareness of important issues. All our people complete training on anti-racism and cultural inclusion as well as topics such as unconscious bias to ensure these principles are embedded throughout the firm.
As a professional services business, our supply chain is relatively simple. We use well-established service providers within the following categories:
· Professional services such as expert panels, primary research agencies, law firms, accounting firms, insurers and pension providers
· Technology such as major software publishers and IT hardware suppliers
· Travel such as airlines and hotels
· Business services such as office space, well known employment agencies, housekeeping staff and basic office supplies.
Given that the majority of our people and suppliers are skilled workers operating in developed markets, we consider the risk of modern slavery in our supply chain to be low.
However, we understand that modern slavery persists in plain sight throughout the world, and no industry is immune to its terrible reach. We therefore periodically review our assessment of modern slavery risk in accordance with our risk management framework.
Governance and reporting
Our Audit & Risk Committee ensures the integrity and effectiveness of OC&C’s risk management framework. It routinely and methodically considers all risks facing the business and makes recommendations based on the overall circumstances.
Where a heightened risk of modern slavery is detected, responses may include working with the relevant supplier to resolve the matter or, where we cannot satisfactorily resolve things, terminating our arrangement. If appropriate, we will alert relevant authorities.
We maintain an effective mechanism to confidentially report any concerns or suspicions related to unethical or illegal practices, such as health and safety issues, fraud, bribery or modern slavery issues. Our external whistle-blower service is entirely confidential and can be used by our people to report issues or concerns.
Reports through the whistle-blower hotline are received by an independent dedicated provider. All matters are treated sensitively and seriously, and we always take appropriate action to remedy identified issues.
Our ESG journey
ESG is an intrinsic part of both our core strategic work for clients and the way our business operates more widely.
We’ve made ESG a key pillar of our corporate strategy and created a Head of ESG role as part of our executive committee to ensure that the
topic is truly at the centre of all decision-making and leadership. We’ve even incorporated a commitment to positive ESG impact into our legal founding documents.
We are proud to have released our first edition of the OC&C ESG Impact Report, which sets out in detail our recent efforts in this area. A copy of the ESG Impact Report is available here.
Our path ahead
We recognise that there is continuous improvement to be made to reduce the risk of modern slavery in our business and supply chain. We will achieve this by:
· Continuing our journey to become an industry leader in ESG commitment and transparency
· Developing employee awareness and expanding our existing training programme, including targeted training on modern slavery for people with direct responsibility for procuring goods and services and managing suppliers
· Reviewing and developing our risk management framework
· Improving our procurement practices, such as supplier adherence to certain minimum standards and enhanced due diligence, as appropriate.
We look forward to updating you in the years ahead.
Global Managing Partner
26 October 2023
This statement is approved for and on behalf of OC&C Strategy Consultants LLP and its applicable subsidiaries in accordance with section 54(1) of the Modern Slavery Act 2015 for the financial year ending 30 April 2023.