Our business and values

Gravita provides a range of accounting and professional finance services within the UK to both institutional clients and entrepreneurs. Given the nature of Gravita’s operations, it is at very low risk of exposure to slavery and human trafficking issues. However, the Group takes its responsibilities very seriously with a zero-tolerance approach to slavery, human trafficking or forced labour in any part of our business or supply chain.

Everything we do is driven by our core values, which define how we work with our clients, colleagues, supply chain and the wider communities within which we work. These values of being ambitious, caring deeply, valuing relationships, communicating clearly and getting things done encompass our relations with our colleagues, suppliers, contractors and stakeholders, whom we expect to respect and reflect our values in the manner in which they work with us.

Policies in relation to Slavery and Human Trafficking

Gravita recognises the role it shares with its suppliers and other contacts in tackling the growing issues of slavery.

We have various practices, procedures, and policies to ensure compliance with all human rights laws and UK employment laws. Our Staff Handbook states the Group has zero tolerance for slavery and human trafficking and places a duty on all members of the Gravita team to report any potential infringement arising either internally or externally. At the Group induction event – held for all new joiners within two months of their joining – there is a specific training session on issues relating to slavery and human trafficking.

Key policies include:

• Equal Opportunities Policy
• Whistle-blowing Policy
• Health and Safety Policy
• Grievance Procedures

Gravita is also committed to paying its team members not less than the current Living Wage (which exceeds the UK’s national minimum wage).

Supplier due diligence

The relevant teams at Gravita monitor providers and contractors and require evidence that significant suppliers have confirmed their compliance with the MSA. During the 2021/2022 fiscal year no contracts were terminated because of non-compliance.

On-going developments to Gravita’s key supplier due diligence process and the on-going review of their contracts are scheduled to continue during 2023/2024.

The majority of our supply chain is made up of service providers based in the UK who we consider are generally at a lower risk of modern slavery and human trafficking than some overseas service providers. Where we outsource or place reliance on key suppliers in higher risk jurisdictions, we seek to put in place clear contractual obligations with regards to anti-slavery and human trafficking laws or ensure they are required to comply with international human rights laws. Clear processes and controls are in place with all suppliers and providers, such as cleaning contractors, recruitment consultants, law firms, design agencies, and IT software and hosting providers.

We regularly assess and review anti-slavery matters with existing suppliers when contracts are reviewed and/or renewed, and at inception with new suppliers. This includes, where appropriate, the insertion of provisions into written contracts which oblige suppliers to comply with the MSA and hold them to the same standards that Gravita applies to its own business. If any organisation within its supply chain is unable to demonstrate their commitment to their obligations, they will not be taken on as a supplier or their services will be terminated.

Actions taken and planned

Throughout the 2022/2023 financial year, the Group has continued to build on the approach introduced over the past few years. Activities have included:

Training

Training remains front and centre on slavery and human trafficking and as of 2023 it is included within our annual compulsory training for all members of the Gravita team in the business to further ensure that everyone is aware of all their rights and obligations. This training is also part of the Gravita’s new joiner induction, which is a requirement for all new, part and full-time hires. Our training aims to encourage all people at Gravita to be aware of potential signs of modern slavery throughout the Group including in relation to suppliers, clients and other counter parties.

Support and Awareness

Through our whistleblowing procedure, staff are encouraged to report any concerns in confidence and anonymously via various routes. Gravita appreciates that individuals need to feel able to report suspected wrongdoing without recrimination and that there needs to be an understanding of the difference between respecting client confidentiality and the requirement to report suspicions of illegal activity for the public good. Gravita has policies in place that are in line with the ICAEW’s Code of Ethics including the aspects relating to Non Compliance With Laws and Regulations that outline the legal and regulatory requirements to disclose. Internal concerns are expected to be discussed in the first instance with a line manager or a member of the executive. Whilst respecting confidentiality, matters of concern can be escalated  to the executive management team and the Board, so that they can be dealt with effectively.

If a concern relates to suspected criminal activity such as fraud or money laundering there are guidelines on how to contact the appropriate authority or entity (such as the securities regulator for suspected fraudulent financial reporting or the environmental protection agency for a suspected breach of environmental laws and regulations).

There is regular engagement with members of the Gravita team including an ability to voice concerns at the monthly All Hands sessions and our annual online survey which enables people working at Gravita to raise issues of concern, including worries over slavery, bullying and discrimination. During 2021/22 and in 2023 to date no concerns relating to slavery, bullying and discrimination were raised. Further surveys will take place over the forthcoming financial year.

Commitment

We remain concerned and committed to tackling slavery where we can, within the Group, through our suppliers and within the wider communities in which we operate.

Signed for and on behalf of Gravita by:  Caroline Plumb

Approved February 2023