ANTI MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2024

INTRODUCTION 

This statement is published in accordance with section 54(1) of the Modern Slavery Act 2015 and sets out the approach that Marbral Advisory has taken over the past 12 months, with aim of ensuring modern slavery or human trafficking is not present in our business or our supply chains. 

Through coercion of service provision, modern slavery involves the illegal exploitation of people for personal or commercial gain. It is therefore a fundamental human rights violation and a serious crime. 

OUR BUSINESS AND ORGANISATION STRUCTURE 

Marbral Advisory is a consultancy that supports organisations and individuals to plan, lead, drive and embed change. As boutique change specialists, we make change wanted, happen and stick; an ethos that is at the core of what we do. Marbral operates at the intersection between people, processes, and technology and specialises in business change, organisational change and the ‘people’ element of transformation. You'll find us working in the financial, legal, logistics, technology, utilities, construction and government space. Our CEO is Leonie McCrann and we have a presence in Jersey, Guernsey, Isle of Man, the UK, Portugal and Malta. 

OUR POLICIES 

Our company stands for the core values of synergy, honesty, and integrity. 

As such, we expect all members of Marbral Advisory to be directed by the same values in their judgment and behaviour and follow our Code of Conduct and Ethics Policy. This includes complying with all environmental, trading, safety, and privacy laws, as well as client codes of conduct. 

We expect all of our UK clients with operations in the EU to comply with local legislation. For companies that operate solely in the UK, national laws, such as the Public Interest Disclosure Act 1998 and the Employment Rights Act 1996, provide extensive whistleblower protection. Across the European Union, we expect companies to have robust legislation guided by the European Whistleblower Protection Directive. 

The majority of our workforce are members of professional bodies, and we expect all our people to abide by the code of conduct of their professional associations. 

All employees should respect their colleagues, supervisors, and customers. Any discriminatory behaviour or harassment will not be tolerated. 

Employees who repeatedly or deliberately fail to follow our code of conduct will meet an appropriate disciplinary action. 

RISK ASSESSMENT AND DUE DILIGENCE 

Marbral provides professional services primarily in the Channel Islands, which are considered lower risk for modern slavery. 

Whilst we have worked in the construction industry on previous occasions, which is considered higher risk for modern slavery, Marbral has not undertaken any work in this sector this financial year. 

Our recruitment policies include ensuring that all candidates produce documentation confirming that they have the right to live and work in the relevant location, prior to commencement of contract. 

As part of our first Anti-Modern Slavery Statement, we undertook a survey of all suppliers to establish a snapshot of our supply chains. 

Questions include asking them to confirm whether they have an Anti-Modern Slavery Statement available, whether they operate as an ethical recruiter/hirer, pay their jurisdictional living wage, the frequency of supply chain review and what steps they take to ensure these risks are not present within their own supply chains. 

The aim is to work with suppliers who meet or are actively working towards meeting the criteria set out in the form, I.e. in the process of compiling their own Modern Slavery Statement. 

We will continue to contact suppliers on a regular basis, to confirm that they continue to share our zero-tolerance approach to modern slavery. 

From this, we have reason to believe that the risk of modern slavery and human trafficking within our business remains low. 

AWARENESS AND TRAINING 

We have established a social value working group who have been researching into modern slavery as part of a range of commitments for our business. All new joiners receive the company handbook containing our company policies, commitments and statements. They then undertake an induction session and complete mandatory training on topics such as GDPR, Anti-Bribery and corruption, DSE and Cyber Security. Effective Sustainability for business training and wellbeing training is also made available to them. Diversity and Inclusion training is currently being developed to roll out to the team which will include a module on ethical practices and our stance on modern slavery. 

This statement will be shared annually with all our team. 

FURTHER STEPS AND MEASURING EFFECTIVENESS 

Marbral Advisory is committed to championing social value and to ensuring ethical working practices both within our own business and within the businesses we choose to work with. The supplier questionnaire is administered to all of our suppliers in line with best practice standards to make sure we are being diligent and consciously aware of our supply chain practices. 

There have not been any reported incidents of slavery or trafficking during the year. 

Leonie McCrann 23rd February 2024 

CEO