Modern Slavery & Human Trafficking Policy Statement

Managing Director’s Introduction

Slavery and human trafficking is rightly being given a much higher priority as a global problem facing millions of people and the way that they are forced to live. The UK government has legislated to encourage businesses to play their part more overtly and this statement is the 3Graces’ contribution to this call for action.

Our Organisation Structure

We are a provider of interim management service to clients on an international basis at CEO level. We also take NED, coaching, mentoring, advisory and consultancy roles. As a business, we are a micro-enterprise but when on assignment, we carry the responsibility for the well-being of the client organisation. This may be a complex company covering a number of sites and countries employing many thousands of people with an international supplier and customer base.

Our Supply Chains

As the 3 Graces is a micro-enterprise, our supply chain is very simple, with professional service businesses based in the UK being our main expenditure, along with IT companies. We do not expect to confront difficulties with such suppliers but have asked for guidance regarding their policies and statements where not found on line.

Our Customer Base

The 3 Graces is enrolled under the anti-Money Laundering Regulations and as such already takes care to ensure that potential and actual clients are behaving within the Act. Given the requirements of the Modern Slavery Act 2015, this will be treated similarly in the way that we assess the client base prior to and during any assignment.

The 3 Graces’ Policies on Slavery & Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our value-added chain. Our company is committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

This approach is also consistent with the Institute of Interim Management’s Code of Conduct
( ) that all accredited members must sign up to. I am committed to this code as a full member of the IIM, an elected Companion and having been involved with the IIM Board that wrote the code initially.

As an accredited executive coach, our Managing Director is a full member of the Association for Coaching and complies with the global code of ethics

( )


Due Diligence Processes for Slavery & Human Trafficking.

As part of our initiative to identify and mitigate risk:

    • Where possible we build long standing relationships with our key suppliers and make clear our culture and expectations of business behaviour;
    • When establishing new customer relationships, we take time to understand their situation, the issues prevalent at that time and what we will do to achieve the client’s goals in a manner that is consistent with the 3 Graces’ culture and in this case, the Modern Slavery Act 2015.
    • Where client circumstances change with time, we endeavour to handle any adverse changes so that the legislation is applied with as soon as practically possible. We ensure that concerns are reported, internal audits are thorough and whistle blowers protected.

Value Added Chain Adherence to Our Values.

We expect all those in our value added chain to comply with our values. This includes a zero tolerance to slavery and human trafficking.

As a micro-enterprise, the two company directors have joint ownership of ensuring our approach and the law are adhered to.


To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, the directors keep themselves briefed on changes in the legislation and variations in approach in countries where assignments are based.

Effectiveness in Combating Slavery & Human Trafficking.

The supplier base is very simple as mentioned previously and is dealt with largely through annual review at the company year end.

When engaged with larger clients on assignment, a number of activities are undertaken that allow good coverage of the client’s situation. These include:

    • Completion of internal audits by independent group personnel.
    • Use of labour monitoring and payroll systems.
    • Application of relevant procedures within the client’s supply chain.
    • Adherence to client customer requirements with respect to the Act.
    • Clear delegated responsibility to senior managers within the client organisation to ensure consistency of approach throughout the company.
    • Ensuring that the HR department has relevant policies in place to support reporting concerns or whistle blowing.

This is the slavery and human trafficking statement for The 3 Graces Co. Limited and is made pursuant to section 54(1) of the Modern Slavery Act 2015.

Tony Evans
Managing Director
The 3 Graces Co. Limited.

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