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Modern Slavery and Human Trafficking Statement 2021

This statement is published on behalf of Ankura Consulting (Europe) Limited (“Ankura Europe”) pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) and constitutes our Modern Slavery Statement for the financial year 2021 ending December 31, 2021. Ankura Europe is committed to preventing modern slavery and human trafficking in our business and our supply chain.

Ankura’s organisation structure and supply chains

Ankura Europe is part of Ankura Consulting Group, LLC (“Ankura Consulting Group”) a global firm of experts and advisors uniquely built to help clients tackle each challenge or need, by effectively combining the right expertise into solutions, services, and results. Further information about our business, our values, our structure, our areas of expertise, the industries and countries in which we operate, can be found on our website at Home - Ankura.

Ankura Europe’s supply chain consists of suppliers of goods and services to support the services we in turn supply to our clients. 

Ankura’s policies in relation to slavery and human trafficking

Ankura Europe has a zero-tolerance approach to modern slavery. The Act defines “modern slavery” as “slavery, servitude and forced or compulsory labour” as well as human trafficking.  Ankura uses the same definition of “modern slavery” in this statement.  

 We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place anywhere in our own business or in any of our supply chains. 

Ankura Consulting Group operates pursuant to a number of Corporate Policies which apply globally, including a Modern Slavery and Human Trafficking Policy and a Whistleblowing Policy. 

Our Modern Slavery and Human Trafficking Policy specifically underscores our company’s zero-tolerance policy, and applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. 

Ankura upholds individual human rights in all of its operations.  In part, this means that Ankura provides reasonable working hours and fair wages for those who work on its behalf.  Ankura opposes the use of modern slavery in all forms and has zero tolerance for the use of child labour, or human trafficking practices, whether within its businesses or its supply chains.  Further, Ankura will not knowingly do business with sub-contractors, business partners or suppliers who violate these practices.  

Ankura has created a safe, healthy and inclusive workplace with a strong culture of collaboration and respect for others.  This is evidenced by our numerous policies and internal groups focused on diversity and inclusiveness which reflect Ankura’s values. 

All employees are encouraged to report any concerns regarding suspected breaches of our internal policies or procedures, concerns of improper conduct or violations of applicable laws to their manager or report it in accordance with our Whistleblowing Policy which operates a confidential 24-hour internet-based reporting system. 

Our policies were reviewed in 2021 to ensure they reflect best practice and reflect our zero-tolerance approach to modern slavery and updated versions will be released in early 2022. 

Strategy and supply chain due diligence

We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery and human trafficking throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. 

Ankura’s key suppliers are the businesses which help Ankura furnish its office premises (e.g. utilities) or who supply the firm with technology, infrastructure and other support needed to run the business and serve our clients (e.g. IT, telecoms, recruitment, stationary and supplies).  

Our supplier relationships are based on lawful and fair practices. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our supplier onboarding process we will be including screening questions and specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we require that our suppliers will hold their own suppliers to the same high standards. Ankura Europe will not knowingly use any supplier that uses forced, prison or indentured labour. 

Ankura will continue to focus on our existing supply chain to identify additional steps that can be taken to ensure minimising the risk of slavery or human trafficking.

Risk assessment and management

Ankura Europe’s assessment is that there is a low risk of slavery or human trafficking occurring within its business, which is commensurate with other professional services firms. 

There is a greater risk of slavery or human trafficking occurring within our supply chains, though this is still perceived as low overall. We will be analysing our supplier base in 2022 in order to focus our assessments on higher risk suppliers and will develop this approach during 2022.  

In 2021 a cross-department working group was established to regularly assess and progress our activities in relation to modern slavery and human trafficking.

Training

All employees across our EMEA & APAC offices, both internal and client facing, were sent an online Modern Slavery course in 2021. This training is compulsory and helps our employees to understand where the risks of slavery and human trafficking could arise in our business and supply chain and what to do about it. 

In 2022 we will also be looking into providing further specific training for those involved in our procurement processes. 

Board approval

This Modern Slavery Statement has been reviewed and approved by Ankura Consulting (Europe) Limited’s Board of Directors.

Simon Michaels 

Chairman for EMEA and APAC

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