This statement summarises the steps that Control Risks has taken to ensure that slavery and human trafficking are not taking place
either within our business or in our supply chains. The statement refers to the financial year ending in April 2018 in accordance with
Section 54 of the Modern Slavery Act 2015.
Control Risks is a specialist risk consultancy that helps to create secure, compliant and resilient organisations in an age of ever-
changing risk. We work across the world from a network of 37 offices and operate in accordance with shared standards and
principles. Employing around 2,500 people from highly diverse backgrounds, we work with clients from the public, private and non-
profit sectors. We have worked for clients from all industry sectors in more than 150 countries.
Our ethical commitment
Our Code of Ethics summarises our commitment to business integrity. Our Human Rights Policy provides further elaboration.
The policy affirms that “Control Risks has zero tolerance for modern slavery and human trafficking”. Furthermore, the company is
“committed to implementing effective systems and controls to ensure that neither practice is occurring anywhere in its supply chains”.
We have been a signatory to the UN Global Compact since 2007, and issue annual Communications on Progress affirming our
application of the Compact’s ten principles, including with regard to labour rights.
In our capacity as a professional services firm, we judge that the risk of slavery or human trafficking existing within our own business
is low. However, in response to the Modern Slavery Act, we keep the risk of slavery or other forms of labour malpractice within our
supply chain under constant review.
In our initial risk assessment following the enactment of the Modern Slavery Act, we took particular account of the Global Slavery
Index with a focus on high-risk jurisdictions. However, while geographical patterns of risk remain an important factor in our analysis,
we have also been alerted to the exposures that may apply in particular sectors, including in countries with high governance
standards that might otherwise be considered low-risk.
One of the findings of our ongoing risk review is the need to place a particular focus on our relationship with suppliers of personnel
such as cleaning or driving services, noting that in many jurisdictions such services are provided by low skilled or migrant workers who
may be more vulnerable to exploitation. We have therefore been placing such suppliers under closer scrutiny. In acknowledgement of
these potential exposures, we have taken steps to enhance our procedures for engaging with these service providers.
Modern Slavery Act Statement: October 2018
Supplier Management Policy and Procedures
In late 2017 we launched our Supplier Management Policy and Procedures. A key principle of the policy is that the selection and
management of suppliers must “minimise the risk of illegal, unethical or unprofessional behaviour” and, specifically in relation to labour,
“where a supplier provides personnel to Control Risks it should have ethical employment practices”.
As part our engagement procedures, we require suppliers of personnel to complete a “Labour Questionnaire” covering their
own recruitment and employment practices, for example with regard to the payment of overtime and the availability of grievance
mechanisms. We evaluate their responses carefully, drawing on the expertise of our own regional and subject matter specialists
We also ensure that supplier contracts contain appropriate provisions regarding compliance with applicable anti-slavery and human
trafficking laws and regulations, including the right to audit.
We are now planning a special campaign across our global office network to raise awareness of the relevant vetting and training
procedures for managing these supplier relationships.
In the case of a small number of particularly complex or high-risk projects, we set up an additional risk committee which is responsible
for reviewing risks – including potential labour welfare concerns – at regular intervals. The project risk committee does this in
association with – but independently of – the project management team. The committee may also recommend supplementary
country-specific implementation procedures, including with regard to labour welfare risks, to reinforce the implementation of our
human rights commitments.
Modern Slavery Act Statement: October 2018
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