This statement sets out the steps that Barnes Roffe LLP (the Firm) has taken to ensure that comply with the Act and that modern slavery and / or human trafficking does not take place within our own business or our supply chain.

Whilst Barnes Roffe LLP does not meet the threshold above which it is statutorily required to issue a Modern Slavery Act Statement, the Firm considers it best practice and has therefore set out its policy of compliance with the Modern Slavery Act 2015.

Barnes Roffe LLP

The Firm is a limited liability partnership of chartered accountants and tax advisors located in five offices in and around London. We draw on the expertise of over 200 professionals to provide a quality service to our client base. Our core work is to provide audit, tax and business advice to our predominantly UK-based clients.

Supply Chain

Given the nature of the firm’s business, we have determined that our primary area of focus for the purposes of addressing the risk of slavery and human trafficking in our business lies in our supply chain. The supply chain includes professional service advisers, who we instruct on assignments, who are regulated by their own recognised supervisory bodies.

Other suppliers include cleaning and catering, hospitality, IT equipment, software and consultancy, office consumables such as stationery and office fit out and maintenance, travel and accommodation. Although most of the suppliers that we deal with are based in the United Kingdom, some have overseas parent companies, and others have international supply chains themselves. It is possible that some of these include jurisdictions where there is a higher risk of modern slavery or human trafficking.

We expect all our suppliers and advisers to be similarly opposed to slavery and human trafficking.

The Firm assess this to result in a low risk that any of its suppliers will be involved with slavery or human trafficking.

Offshore Service Providers

The Firm does engage with non-UK service providers in respect of accountancy and back-office services. We have put in place measures to ensure that the workers in the service providers are properly and adequately remunerated and that their working environment and conditions are appropriate and suitable.

Policies and Procedures

The firm strives to maintain the highest standards of conduct and ethical behaviour. The Firm has a code of conduct which outlines the behaviour expected of team members both professionally in the workplace and personally outside of the workplace. Team members are made aware of the actions and behaviours that are expected of them when representing the Firm, and there are clear employment policies and procedures in place which they are expected to comply with. These policies and procedures are reviewed and updated as necessary and are clearly and regularly communicated to all team members.

Recruitment

The firm adopts recruitment processes in line with UK employment legislation, including identity verification checks, right to work document checks, evidence of qualifications and reference checks. Our recruitment methods include direct advertising, direct referrals from the Firm’s team members and reputable agencies.

Equality, Diversity and Inclusion

The Firm is committed to providing equal opportunities in employment and to avoiding unlawful discrimination against members of staff and job applicants. Innovative thinking and different ideas are critical to the firm’s success and its ability to develop new ways of adding value for its clients. The Firm and our services will be greatly enhanced by having a diverse workforce who can bring differing experiences and perspectives to the workplace. The Firm has a policy in place and provides appropriate training in support of this commitment.

Whistleblowing

The Firm encourages all team members to report any concerns they may have about the conduct of others in the business, including any criminal activity or the way in which the business is run. Team members can make disclosures without fear of retaliation or detrimental treatment and are clear of the processes to be used should they have any concerns.

Compliance

The Firm fully embraces and maintains high standards of compliance procedures relating to Investments, Anti-Money Laundering, Audit Compliance, Anti-Bribery, Corporate Criminal Offences and Professional Conduct in Relation to Taxation. These procedures are regularly reviewed and communicated internally, all team members are provided with training on these procedures and sign off on their training and acceptance of the procedures on an annual basis. All new staff also must sign their agreement at commencement of their employment as part of their induction process.

Ethical Standards

The Firm and all our team members demonstrate high standards of professional conduct by adopting and following the ICAEW Code of Ethics throughout all our professional and business activity whether remunerated or voluntary.

Client Onboarding

As part of our client onboarding and ‘know your client’ processes, we consider whether there could be a conflict of interest with our values or the interests of any existing clients and ensure that by accepting an engagement that there is no conflict of interest. This statement was approved by the Members of the Barnes Roffe LLP on 24 April 2024