Modern slavery statement 2025

As relates to Financial Year End 31/12/2024

Introduction

Per the (UK) Modern Slavery Act 2015 all bodies corporate and partnerships who (irrespective of where they are incorporated) (1) carry on a business, or part of a business, in the UK supplying goods or services, and (2) have a consolidated global turnover of above £36 million (or Euro equivalent) per annum, are required to prepare and publish an annual “Slavery and Human Trafficking Statement”.¹

This statement must set out the measures an organisation has taken during its financial year to ensure that slavery or human trafficking is not taking place in any of its supply chains or within itself.¹

The Republic of Ireland has similar legislation, primarily the Criminal Law (Human Trafficking) Act 2008, as amended by the Criminal Law (Human Trafficking) (Amendment) Act 2013.²

In this context, this statement is to be read as applying to Grant Thornton Ireland* (Republic of Ireland, Northern Ireland, Isle of Man, Gibraltar and Bermuda) entities.

Modern slavery

Modern slavery is an international crime affecting an estimated 50 million individuals around the world (in 2021)³, approximately 28 million in forced labour and 22 million in forced marriage.  This global issue transcends age, gender and ethnicities; it is estimated that 1 in 3 victims of forced labour are women and girls.⁴

Modern slavery relates to exploitation of children and adults in slavery, servitude, or forced or compulsory labour. Human trafficking is the recruitment, movement, harbouring, or receiving of children, and of adults through coercion, deception, or force, for the purposes of exploitation.⁵ 

“Human trafficking” is a global crime that trades in people and exploits them for profit.

“Human trafficking” is defined in the UN Trafficking in Persons Protocol, which supplements the United Nations Convention against Transnational Organized Crime, as “the recruitment, transport, transfer, harbouring or receipt of a person by such means as threat or use of force or other forms of coercion, abduction, fraud or deception for the purpose of exploitation”.

Although human trafficking often involves an international cross-border element, it is also possible to be a victim of modern slavery within your own country. There are several broad categories of exploitation linked to human trafficking, including sexual exploitation, forced labour, domestic servitude, organ harvesting, child related crimes, forced marriage and illegal adoption.⁶

Modern slavery and human trafficking are seen to manifest in four key types of exploitation:

• domestic servitude;
• exploitation in criminal activity;
• labour exploitation; and
• sexual exploitation.

Although victims of modern slavery and human trafficking are of both sexes, it is a highly gendered crime, with male victims most often exploited for their labour and in criminal activity, and female victims the majority in both sexual exploitation and domestic servitude.⁵

Modern slavery includes victims who have been brought from overseas and vulnerable people in the UK, Isle of Man and in Ireland who are forced to work illegally against their will. This is across many different sectors such as agriculture (including illegal drug cultivation), beauty services, construction, food processing and preparation and car wash services.⁵

Estimates of the number of victims of modern slavery in the UK and Republic of Ireland remain high. The 2023 Global Slavery Index³ estimated approx. 122,000 such individuals in the UK, with approx. 5,000 in the Republic of Ireland.

It has been estimated that globally modern slavery generates as much as $150bn – 245bn USD in profits every year with more than a third of these profits generated in developed countries, including the UK, Isle of Man, Gibraltar, Bermuda, and the Republic of Ireland.⁷

The (UK) National Crime Agency (NCA) identified in their Indicators of Modern Slavery and Human Trafficking in the Accountancy Sector⁸ guidance what they consider the key areas where they deem there to be greater risk and visibility of modern slavery and human trafficking.

This NCA guidance is included as an Appendix in the Grant Thornton Ireland Anti-Slavery and Human Trafficking Policy so to assist staff (those operating in Republic of Ireland, Isle of Man, Gibraltar, Bermuda or Northern Ireland) better identify potential real-world risks or actual instances in relation to modern slavery and human trafficking.

That NCA guidance has also been considered and has influenced the content of this statement and of the policy, as well as communications and training relating to this topic.

Our structure

Grant Thornton is a group of partnerships formed under the Partnership Act 1890. It comprised 68 partners on 31 December 2024. It is regulated by IAASA, PSCAI and the Public Company Accounting Oversight Board (PCAOB).

Grant Thornton (NI) LLP, the audit practice in Northern Ireland, was wholly owned and controlled by Grant Thornton throughout 2024. It is regulated by PSCAI and the FRC. With effect from 3 January 2025, the Grant Thornton Ireland group of companies has been reorganised as an alternative practice structure (APS).

Following the reorganisation, Grant Thornton and Grant Thornton (NI) LLP continue as separate licensed audit firms. Grant Thornton and Grant Thornton (NI) LLP are wholly owned and managed by their respective partners.

Grant Thornton Holdings Limited, which owns several Grant Thornton trading entities that provide non-audit services only, has been acquired by Grant Thornton Advisors LLC, a Grant Thornton member firm in the US (GT US) with a noncontrolling interest backed by outside investors.

Grant Thornton Holdings Limited provides personnel, administrative and operational support to Grant Thornton and Grant Thornton (NI) LLP in line with an administrative services agreement (ASA).

The firm also conducts certain types of business through several incorporated entities, as set out in the table on the next page. The firm additionally conducts business in the Isle of Man, Gibraltar and Bermuda through locally incorporated entities. These are regulated by the local regulatory authorities in those countries as applicable.

Grant Thornton Ireland is a full member firm of Grant Thornton International Limited (GTIL) which is a not-for-profit, non-practicing, international umbrella membership entity organised as a private company limited by guarantee not having a share capital, incorporated in England and Wales.

GTIL is one of the world’s leading organisations of independently owned and managed accounting and consulting firms..

Further details on the structure of Grant Thornton Ireland are available in our latest Transparency Report available on our website.

Our policy

The policy of Grant Thornton Ireland is to conduct all of our business in an honest and ethical manner, and to comply with all applicable legislation. We strive to ensure that neither modern slavery nor human trafficking supports our supply chain or our businesses; this objective is implicit in our policies and procedures. We aim for a zero-tolerance approach to violations of anti-slavery and human trafficking laws.

If breaches of these laws are found within our supply chain, we will look to support organisations in their efforts to comply with the applicable legislation. We will review the continuation of business with individuals and organisations found to be involved in slavery, human trafficking, forced or child labour and retains the right to cease business with such individuals and organisations on this basis.

We are committed to acting professionally and with integrity in all its business dealings and relationships.

In this context, Grant Thornton Ireland has a dedicated Anti-Slavery and Human Trafficking Policy.

We will review this policy and its operation in practice, at least on an annual basis.

Reporting knowledge or suspicion of slavery or human trafficking

All employees, partners and principals within the firm have a statutory obligation to report knowledge or suspicion of slavery or human trafficking. Any genuine suspicion or knowledge of slavery or human trafficking is to be immediately reported to the relevant Engagement Partner and to the Head of Risk and Quality, who will decide what further action, if any, is deemed necessary.

If the issue reported also relates to knowledge or suspicion of money laundering or terrorist financing (or proliferation financing) then a further report is to be submitted to the relevant office’s/ firm’s Money Laundering Reporting Officer (MLRO). In addition, our Whistleblowing Policy provides for alternative avenues for reporting, including in respect of suspicion or knowledge of slavery or human trafficking.

Partners, principals and employees who raise concerns of slavery or human trafficking in good faith may do so without fear of discrimination or reprisal.

These provisions do not replace any legal reporting or disclosure requirements. Where statutory reporting requirements and procedures exist, these must be fully complied with.

Our Anti-Slavery and Human Trafficking Policy also includes contact details for the following in respect of potential external reporting:

The UK Modern Slavery Helpline, which can be contacted at (0044) (0) 8000 121 700 or via their website at modernslaveryhelpline.org. Alternatively, you can phone the (UK) police on 101 (in an emergency 999).⁹

In the Republic of Ireland, if you are a victim of modern slavery or human trafficking, or you spot a suspected case, you can contact the Migrant Rights Centre Ireland at (00353) (0) 1 889 7570, or email info@mrci.ie¹⁰.

In the Republic of Ireland, if you consider yourself, or someone you know, to be a victim of human trafficking, you should report your concerns to the Garda Síochána (Irish police force). In an emergency, you should call 999 or 112.

If you wish to report suspicions of human trafficking confidentially you can call the Garda Confidential Line on 1800 666 111 or Crimestoppers on 1800 250 025. You can also email suspicions or concerns you wish to share with the Garda Síochána (Irish police force) to blueblindfold@garda.ie¹¹.

During the financial year ended 31/12/2024 the Risk, Compliance & Professional Standards Team of Grant Thornton Ireland did not receive any reports related to knowledge or suspicion of slavery or human trafficking.

Clients

Our client acceptance and ongoing monitoring procedures include detailed risk assessments of each client from an anti-money laundering, counter-terrorist financing, counter-proliferation financing, and wider risk perspective.

These include a review for potential publicly available indications of previous or current involvement with criminality, including modern slavery and human trafficking, as well as consideration of potential high risk countries.

Staff are also to consider the client-reliant risk factors the (UK) National Crime Agency (NCA) identified in their Indicators of Modern Slavery and Human Trafficking in the Accountancy Sector guidance (with reference to the Appendix of the Anti-Slavery and Human Trafficking Policy).

The majority of our clients are situated in countries (Ireland, UK, etc.) with among the lowest prevalence of modern slavery, the highest degree of government response to modern slavery, and the lowest level of vulnerability to modern slavery (as per the Global Slavery Index 2023³).

We have included appropriate anti-slavery and human trafficking provisions into our Republic of Ireland and Northern Ireland terms of business with clients.

Employment procedures

Grant Thornton Ireland has procedures in place pertaining to our employment practices.

• Robust recruitment processes in line with Republic of Ireland, Northern Ireland (UK), Isle of Man, Gibraltar, and Bermuda employment law (as applicable), including “right to work” document checks, contracts of employment, and checks to ensure all employees are above minimum working age (16).
• Market-related pay and reward, which is reviewed annually and linked to professional services firms benchmarks.

Supply chain and procurement

We recognise that our firm is exposed to a greater slavery and human trafficking risk when dealing with suppliers of products and services, particularly those who have operations and suppliers in other territories.

However, Grant Thornton Ireland considers that we, and the majority of our suppliers, are not in industries with a high risk of modern day slavery. Consisting of multiple professional services firms, Grant Thornton Ireland is satisfied that its primary inputs (including from suppliers and vendors) have low levels of potential exposure to modern slavery and human trafficking, though we recognise very limited exposure to some suppliers and vendors operating in industries seen to have a higher level of potential exposure to modern slavery and human trafficking (hotels, catering, IT hardware, waste and recycling etc.).

In addition, our supply chains are primarily confined to Ireland, UK, Isle of Man, Gibraltar, Bermuda and other countries with a relatively lower risk of modern day slavery and human trafficking. It is noted that the majority of our suppliers would be situated in countries (Ireland, UK, etc.) with among the lowest prevalence of modern slavery, the highest degree of government response to modern slavery, and the lowest level of vulnerability to modern slavery (as per the Global Slavery Index 2023³).

From a risk management perspective, we identified areas we needed to develop in conjunction with our supply chain, and a risk-based approach has been developed and is constantly reviewed. This approach includes identifying and reviewing suppliers and vendors that fall within industries and/or countries that can carry higher risk, including in respect of modern day slavery and human trafficking.

Grant Thornton Ireland has developed measures to assist in the review and management of these areas of risk, including an enhanced supplier and vendor due diligence take-on review and ongoing monitoring risk assessment process, which is handled by a dedicated Third Party Risk Team.

Grant Thornton Ireland operates an established Third Party Risk Management framework which guarantees to on-board third parties through a formal take on process to ensure the service providers Grant Thornton Ireland engage have the necessary internal governance controls in place to align with our standards. The process provides assurance our suppliers uphold relevant laws, regulations and industry standards. The process is designed to mitigate the risks associated with engaging third parties. 

As noted above we strive to ensure that neither modern slavery nor human trafficking supports our supply chain or our businesses; this objective is implicit in our policies and procedures. We expect our suppliers/ vendors and their representatives to comply fully with the (UK) Modern Slavery Act, 2015, and the (ROI) Criminal Law (Human Trafficking) Act, 2008, as amended by the Criminal Law (Human Trafficking) (Amendment) Act, 2013, and any other applicable prevention of modern slavery legislation.

If breaches of these laws are found within our supply chain, we will look to support organisations in their efforts to comply with the applicable legislation. We will review the continuation of business with individuals and organisations found to be involved in slavery, human trafficking, forced or child labour and retains the right to cease business with such individuals and organisations on this basis. We are committed to acting professionally and with integrity in all our business dealings and relationships. Grant Thornton Ireland expects our suppliers and their representatives to maintain a dedicated Anti-Slavery and Human Trafficking Policy.

Related policies and documents

In addition to the Anti-Slavery and Human Trafficking Policy mentioned above Grant Thornton Ireland has additional related policies and documents. 

Our Whistleblowing Policy is highlighted to employees, partners and principals on a reoccurring basis. This policy facilitates and encourages employees and partners to raise concerns or disclose information, which relates to wrongdoing, illegal practices or unethical conduct, which may come to their attention through work (including concerns that may relate to modern slavery and human trafficking). This includes the facility for anonymous reporting.

We have a number of further Grant Thornton Ireland policies and documents which reflect our objective to act ethically and in line with our legal and regulatory obligations with regard to our employees, partners, principals, clients and our business relationships.

• Transparency Report (available on the Grant Thornton Ireland website)
• Ethics and Quality Management Manual
• Grant Thornton (Republic of Ireland, Northern Ireland, Isle of Man, Gibraltar and Bermuda) Staff Handbooks
• Various office specific Money Laundering, Terrorist Financing, and Proliferation Financing (MLTFPF) Compliance Manuals.
• Anti-Bribery and Corruption Policy

These policies and documents will continue to be reviewed on, at minimum, an annual basis.

Learning

We want to help our employees, partners, principals, clients and suppliers to understand more about these issues and understand how to report any suspicions they may have related to modern slavery and human trafficking.

The topic of Modern Slavery, and our associated Anti-Slavery and Human Trafficking Policy, continues to be flagged in the induction training undertaken by new staff members starting with Grant Thornton Ireland. 

We flag each update of this Statement and of the associated Anti-Slavery and Human Trafficking Policy to all staff members.

We continue to consider, on an ongoing basis, ways to further enhance awareness on the issues of slavery and human trafficking and of our Anti-Slavery and Human Trafficking Policy among relevant employees, partners and principals.

Looking forward

We will continue to develop and implement the measures mentioned above in respect of our supply chain.

Our approach to modern slavery and human trafficking risk will continue to evolve and we will continue to mitigate these risks through the provisions mentioned above during 2025 and beyond.

Grant Thornton Ireland shall take responsibility for this statement and its objectives, and this statement will be reviewed and updated as appropriate.

Signed, Louise Barry, Partner, Head of Risk & Quality, Grant Thornton.

Note

*Grant Thornton Ireland refers to the Republic of Ireland (ROI), Northern Ireland (NI), Isle of Man (IOM), Gibraltar and Bermuda Grant Thornton entities that are members of the Grant Thornton Ireland group of companies.

These include Grant Thornton, Grant Thornton Corporate Finance Ltd, Grant Thornton Financial & Taxation Consultants Ltd, Grant Thornton Business Advisory Services Ltd, Grant Thornton Consulting Ltd (all ROI), Grant Thornton (NI) LLP, Grant Thornton Advisors (NI) LLP (all NI), Grant Thornton Ltd (IOM), Grant Thornton (Gibraltar) Ltd, Grant Thornton (Bermuda) Ltd and Grant Thornton Advisory (Bermuda) Ltd. Additional information provided under the “Our structure” section above.

Sources

1. (UK) Modern Slavery Act 2015 and the guidance issued (PDF - 1575kb) under section 54(9) of that Act and additional (UK) Home Office guidance.
2. (Republic of Ireland) Criminal Law (Human Trafficking) Act 2008 & Criminal Law (Human Trafficking) (Amendment) Act 2013.
3. The 2023 Global Slavery Index. The latest Global Estimates produced by the International Labour Organization (ILO), Walk Free, and the International Organization for Migration (IOM).
4. International Labour Organization (ILO) Global Estimates of Modern Slavery. (Data and research and highlights)
5. As per various (UK) National Crime Agency (NCA) National Strategic Assessments of Serious and Organised Crime 2019 - 2025.
6. United Nations Office of Drugs and Crime (UNODC) – What is Human Trafficking and Human Trafficking FAQs.
7. International Labour Organization (ILO) Profits and Poverty: The Economics of Forced Labour (forced labour and forced marriage) for the $150 billion figure. Hope for Justice review and update of ILO $150 bn figure (to $245 bn).
8. Indicators of Modern Slavery and Human Trafficking in the Accountancy Sector.
9. UK Modern Slavery Helpline.
10. Migrant Rights Centre Ireland.
11. (Republic of Ireland) Department of Justice – Human Trafficking

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