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 2025 to 31 March 2026.

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 by the FRC Board of Directors on 9 September 2026 and will be reviewed annually.

Signed on behalf of the FRC
Richard Moriarty
Chief Executive Officer

Summary

Our commitment to the MSA includes:

  • Dedicated procurement and legal teams with qualified and experienced resource.
  • Raising awareness of the MSA with our suppliers during contract due diligence and through information on our website.
  • An annual review programme and focus on high-risk areas of the supply chain.
  • The use of standardised terms and conditions to incorporate MSA provisions.
  • Annual review of our whistleblowing policy.
  • Delivery of modern slavery awareness training to high-risk areas of the organisation and suppliers.
  • Identifying the impact of the MSA on our activities and our supply chain.
  • Engagement with the Department for Business, Innovation, Science and Trade and nongovernmental public bodies to share best practice.
  • Updated staff training packs, which are also available to key suppliers to support modern slavery awareness.
  • Annual review of 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 have contracts with approximately 200 suppliers and ask each supplier to review our Supplier Code of Conduct. Before engagement, we assess suppliers to confirm that they meet the standards we expect, including compliance with modern slavery legislation.

In the event of modern slavery practices being identified in (a) the delivery of services under 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 if appropriate.
  • Terminate the contract (if applicable and where necessary).

The FRC’s supplier base predominantly consists of UK-based professional services providers, including accounting, legal and IT services. This profile significantly reduces our exposure to modern slavery risk.

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. First, we raise awareness and understanding of how our staff and partners can report concerns without fear of retaliation. Second, we provide information and channels for external stakeholders to raise concerns through our whistleblowing arrangements: https://www.frc.org.uk/about-the-frc/whistleblowing.

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 wherever possible and may also use supplier framework agreements and bespoke terms and conditions where appropriate. We are also a contracting authority under public procurement regulations.

We are committed to the effective management of our third-party expenditure and supplier arrangements. Prospective suppliers must confirm whether they are a relevant organisation under section 54 of the MSA 2015 and, if so, confirm that they comply with the annual reporting requirements of section 54. If any instance of modern slavery were identified in connection with an FRC contract, the FRC would notify the appropriate law enforcement authorities and work with the supplier to resolve the issue and strengthen working practices and/or terminate the contract where appropriate.

Risk Assessment and Management

Due to the nature of our work, we consider the risk of modern slavery and human trafficking occurring within our operations and supply chain to be low. However, we take our responsibility to identify and respond effectively to any incidents very seriously. Over the next 12 months, we will continue to monitor changes in the inherent risk profile of the goods and services we procure, taking account of any updates to UK Government guidance. We have also completed an assessment of our higher-expenditure contracts across the business using our modern slavery assessment tool, with no exploitation issues identified.

Governance

The FRC’s Board is ultimately responsible for our Modern Slavery Statement. We provide regular updates to the Audit and Risk Committee and the Executive Committee on current and emerging risks relating to the FRC’s procurement activities. The procurement team sits within Corporate Services division of the FRC, under the responsibility of the Chief Operating Officer.

Training

Our procurement team receives 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 are checked for a modern slavery statement or equivalent position.
  • All tenders include a Form of Tender requiring suppliers to confirm that modern slavery is not tolerated by them or within their supply chain.
  • Ensuring that all FRC standard contracts include modern slavery clauses.
  • Annually reviewing contracts to ensure supplier compliance is maintained.

Further Activities

The FRC will continue to enhance modern slavery training and awareness by ensuring that appropriate content, guidance and resources are available to all staff.

Read the FRC’s Modern Slavery Statement (2026)

For any queries, please contact [email protected]

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