Modern Slavery Statement

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Modern Slavery Statement

The Financial Reporting Council (“FRC”) is making this statement in accordance with our commitment to meet section 54 of the Modern Slavery Act 2015 (“MSA”). It covers the steps taken for the financial year 1 April 2024 to 31 March 2025.

The FRC does not tolerate any activity which constitutes modern slavery or human trafficking. We expect our suppliers (and supply chain) to maintain the same approach and to have policies and procedures in place to minimise the risk of modern slavery occurring.

This statement was approved on 10 September 2025 by the FRC’s Board of Directors who will review the statement annually.

Signed on behalf of the FRC
Richard Moriarty
Chief Executive Officer

Summary

Our commitment to the MSA includes:

  • Dedicated Procurement team with qualified and experienced resource.
  • Raising awareness of the MSA with our suppliers during contract due diligence and through information on our website.
  • Regular supplier due diligence to check:
    • Adherence to their MSA statement.
    • General practice in this area.
  • The use of standardised terms and conditions to incorporate MSA provisions.
  • Regular review of our whistleblowing policy.
  • Delivery of regular modern slavery awareness training both to staff and suppliers.
  • Reviewing our methodology for identifying the impact of the MSA on our activities and our supply chain.
  • Engaging with the Department for Business and Trade and non-governmental public bodies to share best practice.
  • Updated staff training packs, which are also available to key suppliers to support their awareness of this important issue.
  • Annually reviewing this Modern Slavery Statement.

Our Structure

The FRC is a company limited by guarantee. Our purpose is to serve the public interest and support UK economic growth by upholding high standards of corporate governance, corporate reporting, audit and actuarial work. We monitor the application of the standards and where in the public interest, we investigate and enforce them. Companies that are run to the highest standards and whose reports are trusted for their accuracy and openness make a positive contribution to society by making sound decisions in their own long-term interest and that of all stakeholders.

As a non-department public body upholding high ethical and public service standards, we continually aim to provide a professional, proactive and positive response to our internal and external stakeholders. We are committed to continually improving our policies and practices to meet or surpass key stakeholder expectations.

Supply Chains

We engage directly with 480 suppliers and have a Supplier Code of Conduct that we ask Suppliers to review. We also actively assess each supplier before engagement to ensure they meet the standards we expect, while ensuring they adhere to modern slavery legislation.

In the event of modern slavery practices being identified in (a) the provision of an FRC supplier contract or (b) the FRC business, the FRC will:

  • Notify the appropriate law enforcement agency.
  • Work openly and proactively with key stakeholders to resolve issues and change working practices.
  • Terminate the contract (if applicable).

Policies

We recognise our responsibility to operate our business with effective policies and procedures to be fair and ethical. Relevant policies include:

Employee Handbook: Our robust Employee Handbook incorporates a Code of Conduct, Grievance Policy and Diversity and Inclusion Policy. This key information seeks to ensure all employees understand the work environment and the high standards that they must adhere to.

Recruitment Policy: The FRC operates robust recruitment practices including, but not limited to, adherence to the Civil Service Recruitment Principles. We ensure that the people we hire have the right to work in the UK and that their basic rights as workers are protected. We commit to providing fair wages and benefits and comply with all applicable minimum wage laws in the UK including the London Living Wage.

Whistleblowing: The FRC’s approach to whistleblowing is two-fold. Firstly, we have raised awareness and understanding of how our staff and partners can report concerns without fear of retaliation. Secondly, the FRC provides information and the ability to external stakeholders to be able raise any concerns https://www.frc.org.uk/about-us/policies-and-procedures/whistleblowing/. The FRC reviewed and updated its Whistleblowing Policy in May 2025.

Procurement Policy: The FRC’s Procurement Policy sets out our approach to the fair and equal treatment of all suppliers. The Policy provides a framework of good practice and control mechanisms (alongside adherence to the Public Contracts Regulations 2015 and the Procurement Act 2023).

Procurement

We use standard Terms and Conditions where possible but also use Supplier Framework Agreements and Terms and Conditions from time to time. We are also a ‘Contracting Authority’ under the public procurement regulations.

We are committed to the effective management of our third-party expenditure and supplier arrangements and require prospective suppliers to confirm whether they are a relevant organisation under section 54 of MSA 2015 and, if so, whether they are compliant with the annual reporting requirements of section 54.

Risk Assessment and Management

Due to the nature of our work, we consider the risk of modern slavery and human trafficking occurring to be low. However, we take our responsibility to identify and effectively respond to any incidents of modern slavery and human trafficking very seriously. We continue to monitor any changes in the inherent risk levels of the goods and services which we procure over the next 12 months, in line with any updates to UK Government guidance. We have also completed an exercise to assess all our higher expenditure contracts across the business using our modern slavery assessment tool with no exploitation issues identified.

Governance

The Board is ultimately responsible for our Modern Slavery Statement. We update our Audit and Risk Committee and the Executive Committee regularly on current and future risks in relation to the FRC’s procurement activities. The Procurement team also sit within Corporate Services, under the responsibility of the Chief Operating Officer.

Training

Our procurement team attend training to help identify and respond to suspected incidents of modern slavery and human trafficking.

Internal Controls

We have developed internal control procedures to monitor progress against managing modern slavery risks as follows:

  • All (new) Suppliers (which the exception of Suppliers via a Compliant Framework Agreement) checked for modern slavery statement / position.
  • All tenders include a Form of Tender for confirmation from the Supplier that modern slavery is not tolerated by them / their supply chain.
  • Ensuring all the FRC’s standard contracts include modern slavery clause(s).
  • Regularly review contracts to ensure supplier compliance is maintained.

Further Activities

FRC will continue to enhance its modern slavery training and raise awareness further by ensuring that there is appropriate content, guidance, training and resources available to all staff.

Read the FRC’s Modern Slavery Statement (2025)

For any queries, please contact [email protected]

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