ERM Worldwide Group Ltd and its subsidiary companies (“ERM”) is committed to the international effort to abolish all forms of modern slavery - including slavery, servitude, forced or compulsory labor and human trafficking, as well as child labor.
This statement sets out the measures in place in ERM and the further steps to be taken, to ensure there is no slavery and human trafficking in our business operations and supply chain.
ERM is a leading global provider of environmental, health, safety, risk, social consulting services and sustainability-related services. We have more than 160 offices in over 40 countries and territories, employing around 4,700 people who work on projects for our clients around the world. The key sectors we serve include Oil and Gas, Mining, Power, Manufacturing, Technology, Media and Telecommunications, Chemical and Pharmaceutical.
The Board of Directors and Executive Committee are ERM's highest governing bodies. Our operational and governance structure is further detailed in our Sustainability Report.
Our Supply Chain
Our supply chain include various forms of capital (human, financial and physical), and goods and services. As a professional services firm, our people (human capital) are our greatest asset. Financial capital enables us to grow our business, while physical capital includes our 160 offices and site-based facilities. We require goods and services for our global offices and to support our delivery of projects to clients, including travel management, technical and personal protection equipment and specialist support from subcontractors.
For many years, ERM has been committed to the highest forms of business conduct and ethics in our operations and supply chain. That commitment forms a cornerstone for many of our policies, procedures and our approach to business.
We recognize our responsibility to support and respect the protection of internationally proclaimed human rights, in line with the UN Guiding Principles on Business and Human Rights and the principles of the UN Global Compact, to which ERM is a signatory. Our policy framework and disclosures associated with the Ten Principles of the UN Global Compact are mapped in our 2016 Sustainability Report.
Our business processes are further informed by relevant International Labour Organisation (ILO) Conventions and definitions contained within the UN Universal Declaration of Human Rights. Our company’s Vision and Values express our corporate philosophy of how we conduct business, while our Code of Business Conduct and Ethics provides the basis for professional, respectful and fair dealings in our daily operations. ERM’s Sustainability Policy and Sustainability Approach articulate our commitments to sustainability.
Our Slavery, Child Labour and Human Trafficking Policy prohibits the use of child or forced labor in our business and any involvement by ERM with entities that support prohibited labour practices or human trafficking, including slavery, bonded labor or debt-bondage, or securing labor or services by force, threat, or deception.
ERM’s Global Supplier/Subcontractor Requirements mandate that our subcontractors and suppliers adhere to ERM’s policies. ERM expects its suppliers and subcontractors to adhere to the same commitments in support of business conduct and ethics and sustainability and against all forms of slavery and human trafficking. Accordingly, our standard form subcontractor/supplier agreements oblige suppliers and subcontractors to acknowledge and comply with ERM’s policies in this regard.
Due Diligence and Effective Risk Assessment and Management
ERM has processes in place to support on-going assessment and management of risks associated with our client engagements, direct business operations and business relationships. We will not work with clients, suppliers or sub-contractors who do not share our commitment to high ethical standards.
ERM’s Global Contractor Management Program provides a process for prequalifying contractors, collecting relevant information for more effective decision-making and risk reduction, and adding value to services provided to our clients by reducing their risk around our use of contractors. As the program is implemented around the world, it provides a consistent approach for mandating contractors to adhere to the requirements of our policies and to track their compliance. The program does not currently include suppliers, which are managed by our business units. We will be reviewing global processes for supplier management in the future.
Our Code of Business Conduct & Ethics and this website provide a process for reporting or raising concerns about any wrongdoing to the Group Compliance Officer, in confidence and without fear of retaliation.
ERM recognizes that we are exposed to the risk of slavery and human trafficking in our business operations and supply chains. We believe the greatest risk exists with our subcontractors and suppliers. We recognize different geographic locations and sectors present higher risks of slavery and human trafficking than others. Our global programs, described above, help us to manage this risk.
In addition, during the financial year ending 31 March 2017, ERM will continue to develop and enhance our risk assessment process to allow us to better understand the sectors and locations where our risk of slavery and human trafficking is the greatest. Once that assessment has been completed, ERM will review how we manage those risks, implement and measure our progress in ensuring no slavery and human trafficking in our operations and supply chain.
We will also continue to review our policies, processes and training going forward to make sure they appropriately address our commitment to eliminate slavery and human trafficking from our operations and supply chain. We will ensure we have robust management processes for identifying and managing human rights risks across our supply chain and ensuring awareness among our employees.
Our approach will continue to be informed by our work with clients, multi- stakeholder dialogue and engagement with governments and international organizations. As a leading consultancy we are actively involved in raising awareness and building capacity related to business and human rights and the broader sustainable development agenda. Highlights of our work are available in our 2016 Sustainability Report.
This statement is made pursuant to section 54(i) of the Modern Slavery Act 2015 and constitutes the Modern Slavery statement for ERM Worldwide Group Ltd and its global subsidiaries.
Signed on behalf of the Board of Directors and Executive Committee:
Chief Executive Officer
Signed: 15 September 2016 for financial year 2016 (1 April 2015 to 31 March 2016) for ERM Worldwide Group Ltd and its global subsidiaries.