Apteus Group Modern Slavery Statement
The steps taken by the Apteus Group and all of its companies to ensure that slavery and human trafficking are not taking place in any part of our business or our supply chains, published under section 54 of the Modern Slavery Act 2015.
Contents
1. Introduction, scope and our commitment
2. Our organisation, structure and business
3. Our supply chains
4. Our assessment of modern slavery risk
5. Our policies in relation to modern slavery
6. Due diligence and managing risk in our own business
7. Due diligence and managing risk in our supply chains
8. Training and awareness
9. Raising and reporting concerns
10. Measuring effectiveness (our key performance indicators)
11. Governance, approval and signature
Appendix — Apteus Group companies covered by this statement
1. Introduction, scope and our commitment
This statement is made by Apteus Holdings Limited (company number 16773949) on behalf of the whole of the Apteus Group. It is published pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) and constitutes the slavery and human trafficking statement of the Apteus Group for the financial year, setting out the steps we have taken to ensure that slavery and human trafficking are not taking place in any part of our business or our supply chains.
This statement is issued for, and applies to, the whole of the Apteus Group without exception. It covers Apteus Holdings Limited and every company, subsidiary, business unit and trading name within the Apteus Group (together “Apteus”, “the Apteus Group”, “we”, “us”, “our”), whether or not each entity individually meets the £36 million turnover threshold in the Act. A full list of the group companies to which this statement applies is set out in the Appendix, and it also applies to any business that joins the group in future from the date it joins. Where an individual group company is required to publish its own statement under the Act, this group statement is made on its behalf and satisfies that obligation.
The group includes our statutory audit business, Apteus Audit Limited (company number 16775133), and our regional and specialist businesses, which continue to serve clients under both the Apteus name and established local practice names — including Farries, Kirk & McVean, Hodge Bakshi, Richard Anthony, Lawrence Grant, DSA Prospect and FTS Recovery. This statement covers all of them.
Modern slavery is a crime and a violation of fundamental human rights. As defined by the Act, it encompasses slavery, servitude, forced or compulsory labour and human trafficking, all of which deprive a person of their liberty in order to exploit them for personal or commercial gain. As an ICAEW-regulated audit, accountancy and professional services group, we are committed to acting ethically and with integrity in all our business relationships, and to implementing and enforcing effective systems and controls to seek to ensure that modern slavery is not taking place anywhere in our own business or in our supply chains. We expect the same high standards of everyone who works for us and with us, including our suppliers, subcontractors and business partners.
2. Our organisation, structure and business
The Apteus Group is a UK-based professional services group and one of the fastest-growing consolidators in the UK accountancy profession, with the ambition of becoming a top-20 UK firm. The group is ultimately owned by funds managed by Livingbridge and is structured through a group holding company (Apteus Holdings Limited) and intermediate holding companies, beneath which sit our audit business and a network of regional and specialist operating companies.
Across the group we provide a broad range of services to clients throughout the United Kingdom, including statutory audit and assurance, accountancy and financial reporting, tax, payroll, corporate finance, wealth, HR, forensic, property, probate and recovery and restructuring services. The great majority of our people are professionally qualified or training towards a professional qualification, are members of professional bodies, and are employed under formal contracts of employment which they are free to terminate.
We consider that the professional services sector in which we operate, and the UK in which we primarily operate, are generally regarded as lower-risk jurisdictions and activities for modern slavery, because slavery and human trafficking are prohibited and criminalised by law and our workforce is largely skilled and professionally regulated. Nevertheless, we do not treat this as a reason for complacency: we recognise that risk can arise, particularly through our supply chain, our use of recruitment agencies and lower-skilled outsourced services, and through the acquisition of new businesses, and we remain vigilant.
3. Our supply chains
Our supply chain is predominantly based in the United Kingdom and reflects the needs of a multi-office professional services group. It principally includes:
- information technology, software, cloud and telecommunications providers;
- professional services suppliers, including recruitment agencies, legal advisers, insurers and other regulated firms;
- facilities, property, cleaning, security, catering and office-services providers across our offices;
- outsourced processing and support services, including any offshore or near-shore support arrangements adopted as the group integrates; and
- travel, accommodation, print, stationery and general office suppliers.
We recognise that the higher-risk areas within a professional services supply chain are typically the provision of lower-skilled, labour-intensive on-site services (such as cleaning, security and catering) and the use of recruitment intermediaries. We take a risk-based approach, focusing our due diligence effort where the risk of modern slavery is greatest, while requiring baseline standards of all suppliers.
4. Our assessment of modern slavery risk
We assess the risk of modern slavery both in our own operations and across our supply chain, taking into account the sector, the type of goods and services procured and the geographic location of our suppliers and their workforces. Our assessment is that:
- the risk within our own workforce is low, because our people are predominantly skilled, professionally qualified, directly employed under formal contracts, and paid at or above statutory and living-wage levels;
- the risk within our supply chain is low to moderate and concentrated in outsourced on-site services and recruitment intermediaries; and
- integration and acquisition activity is a specific area of focus: as new firms join the group, we bring their people, suppliers and contracts within the scope of this statement and our group controls, and we consider modern slavery risk as part of onboarding and integration due diligence.
Modern slavery is frequently linked to other economic crime, including money laundering. Our modern slavery risk assessment is therefore aligned with our firm-wide anti-money-laundering (AML) risk assessment and client and supplier due diligence processes, so that indicators identified in one process inform the other.
5. Our policies in relation to modern slavery
We operate a suite of group policies, applied consistently across every Apteus Group company without exception, that together support our commitment to combating modern slavery. These include:
- this Modern Slavery Statement, which sets out our commitment and the steps we take;
- our Supplier Code of Conduct, which sets out the standards we expect of suppliers, including in relation to modern slavery, labour rights and fair treatment of workers;
- our Recruitment and Right-to-Work Policy, under which we carry out eligibility-to-work checks on all new joiners and use only reputable, vetted recruitment agencies;
- our Whistleblowing / Speak-Up Policy, which enables our people and others to raise concerns confidentially, including concerns about modern slavery affecting our people, our clients or our suppliers;
- our Ethics Policy and Code of Conduct, which require our people to act with integrity and to comply with professional and legal obligations; and
- our Anti-Money-Laundering and Onboarding Policy, which supports the detection of exploitation and economic crime, including the making of Suspicious Activity Reports (SARs) to the National Crime Agency where required.
These policies are reviewed regularly and updated to reflect changes in law, regulation and ICAEW guidance. They apply uniformly to every group company, so that the same standard of protection operates wherever within Apteus the activity takes place.
6. Due diligence and managing risk in our own business
Within our own business we take the following steps to guard against modern slavery:
- Recruitment. We conduct right-to-work and identity checks on all new employees, and we engage only reputable recruitment agencies, from whom we seek confirmation that they do not engage in any practice that would amount to modern slavery under UK law.
- Fair pay and conditions. All our people are engaged under formal contracts of employment and are paid at or above applicable statutory minimum and real living-wage levels. We aim to provide a safe, supportive and inclusive working environment.
- Our people. The majority of our workforce is professionally qualified and regulated, and subject to the ethical requirements of their professional bodies, which reinforces a culture of integrity and lawful conduct.
- Acquisitions and integration. As part of bringing new firms into the group, we extend our group policies, onboarding and controls to their people and suppliers, and consider modern slavery and labour-rights risk within our integration due diligence.
7. Due diligence and managing risk in our supply chains
In relation to our suppliers and subcontractors we take, and continue to develop, the following steps:
- We ask new suppliers, as part of onboarding and procurement, to accept our Supplier Code of Conduct or to demonstrate equivalent standards through their own published code or modern slavery statement.
- For suppliers assessed as having a higher exposure to modern slavery risk (for example providers of on-site labour-intensive services), we seek confirmation that they have appropriate policies, controls, monitoring and whistleblowing arrangements in place, and evidence of their own modern slavery assessment where applicable.
- We reserve the right to decline to trade with, or to cease trading with, any supplier that does not meet our expected standards or that we reasonably believe to be involved in modern slavery.
- We integrate modern slavery considerations into our wider environmental, social and governance (ESG) and procurement due diligence, applying a proportionate, risk-based approach.
8. Training and awareness
We provide training and awareness to help our people recognise the signs of modern slavery and understand how to report concerns. Our approach reflects ICAEW guidance for the accountancy profession and the National Crime Agency’s guidance on spotting the indicators of modern slavery. Modern slavery awareness is incorporated within our broader “reporting suspicions” training, alongside anti-money-laundering and anti-bribery training, so that our people are equipped to identify red flags both within our own business and in the affairs of the clients and businesses we advise. This training is provided to new joiners and refreshed periodically for all our people.
9. Raising and reporting concerns
We encourage anyone — whether a member of our team, a client, a supplier or a member of the public — to raise concerns about actual or suspected modern slavery connected with the Apteus Group. Concerns can be raised through our Whistleblowing / Speak-Up arrangements, which allow reports to be made confidentially and without fear of detriment.
Because modern slavery is closely linked to money laundering and other economic crime, our people are also required, where they know or suspect that money laundering may be taking place, to make a Suspicious Activity Report (SAR) to our Money Laundering Reporting Officer and, as required, to the National Crime Agency, in accordance with our AML obligations under the Money Laundering Regulations 2017. Where appropriate, suspicions of modern slavery are also reported to the Modern Slavery Helpline or the police.
10. Measuring effectiveness (our key performance indicators)
Consistent with the Home Office’s updated statutory guidance, which encourages organisations to focus on action and impact rather than statements of intent, we are developing key performance indicators to measure the effectiveness of the steps we take. As the group and its central compliance function mature, these will include:
- the proportion of our people who have completed modern slavery and “reporting suspicions” training;
- the proportion of new and higher-risk suppliers who have accepted our Supplier Code of Conduct or demonstrated equivalent standards;
- the number of concerns raised through our Speak-Up and SAR processes relating to modern slavery, and how they were dealt with; and
- completion of modern slavery risk considerations within onboarding and acquisition due diligence.
We will report on our progress against these measures in future statements and will continue to strengthen our approach in line with evolving law, regulation and best practice.
11. Governance, approval and signature
Responsibility for this statement and for our group approach to modern slavery sits with the Head of Risk and Compliance, Apteus Group, under the oversight of the Board and the Risk & Quality (R&Q) Committee. This statement has been approved by the Board of Apteus Holdings Limited on behalf of itself and every other company, subsidiary, business unit and trading name within the Apteus Group, and will be reviewed and, where necessary, updated annually and following each financial year end.
Appendix — Apteus Group companies covered by this notice
This notice applies to Apteus Holdings Limited and all of the following companies, together with every other current and future subsidiary, business unit and trading name of the Apteus Group, without exception. Company numbers are shown where confirmed; “—” indicates a number that is pending or to be confirmed.
Apteus Group company:
Company number:
Practice / business it operates (where applicable):
Apteus Group company: Apteus Holdings Ltd
Company number: 16773949
Practice / business it operates (where applicable): Group holding company
Apteus Group company: Apteus Midco 1 Ltd
Company number: 16774297
Practice / business it operates (where applicable): Intermediate holding company
Apteus Group company: Apteus Midco 2 Ltd
Company number: 16774581
Practice / business it operates (where applicable): Intermediate holding company
Apteus Group company: Apteus Group Ltd
Company number: 16774985
Practice / business it operates (where applicable): Group operating company
Apteus Group company: Apteus Audit Ltd
Company number: 16775133
Practice / business it operates (where applicable): Audit
Apteus Group company: Apteus London Ltd
Company number: 16821152
Practice / business it operates (where applicable): Richard Anthony; Lawrence Grant
Apteus Group company: Apteus Caledonia Ltd
Company number: 17048294
Practice / business it operates (where applicable): Farries, Kirk & McVean (FK&M)
Apteus Group company: Apteus Wales Ltd
Company number: 16821018
Practice / business it operates (where applicable): Hodge Bakshi
Apteus Group company: Apteus Recovery Ltd
Company number: 17048222
Practice / business it operates (where applicable): FTS Recovery
Apteus Group company: Apteus Oxfordshire Ltd
Company number: 17312860
Practice / business it operates (where applicable): DSA Prospect
Trading / practice names in use across the group include: Farries, Kirk & McVean (FK&M), Hodge Bakshi, Richard Anthony, Lawrence Grant, DSA Prospect, and FTS Recovery. Any business or trading name that becomes part of the Apteus Group is automatically covered by this notice from the date it joins.