Modern Slavery & Human Trafficking Statement
This statement has been published in accordance with Section 54 of the Modern Slavery Act 2015 (the “Act”). It sets out the steps taken by Sumer Group Holdings Limited and its subsidiaries (together, “The Sumer Group”) for the period to 30 June 2024 to prevent modern slavery and human trafficking in their business operations and supply chains.
The Act covers slavery, servitude and forced or compulsory labour, and human trafficking. It imposes a duty on all businesses over a specified size to play their part in ending modern slavery in global supply chains. Section 54 of the Act requires such businesses to publish a statement of the steps taken during the financial year to ensure that slavery and human trafficking is not taking place in any part of their business or in any of their supply chains.
Sumer Group Holdings Limited is the holding company of a group of regional accountancy companies who provides accounting, tax, audit, advisory and business services across the United Kingdom and Ireland.
Given the nature of our business and the types of goods and services that we procure, we believe that our inherent risk of modern slavery is low, with our supply chains being the main area of risk.
1. Structure and business of Sumer Group Holdings Limited
Subsidiaries of Sumer Group Holdings Limited are firms of accountants with approximately 2,000 colleagues. The head office is based at The Beehive Building, Beehive Ring Road, Crawley, Gatwick, RH6 0PA. Sumer Group Holdings Limited started trading in October 2022 and the Sumer Group has approximately 100,000 clients and provides accounting, tax, audit, advisory and business services. The firm’s annual turnover first exceeded the £36 million threshold (at which section 54 of the Act takes effect) in the financial year ended 30 June 2024.
2. Policies in relation to Modern Slavery and Human Trafficking
Sumer has a zero-tolerance approach to modern slavery. The following principles apply to the Sumer Group’s business and its supply chain: (i) child labour must not be used; (ii) any form of forced or compulsory labour must not be used. Workers must be free to leave employment or work after reasonable notice; (iii) passports, visas and other personal documentation should not be taken from employees unless requested to be held by the employee for safekeeping purposes (and, if held for safekeeping purposes, they should be returned to the employee on request); (iv) all forms of debt bondage are prohibited. Workers should not be subject to contracts that tie them into repaying a loan (other than small loans to cover items such as transport costs), excessive accommodation expenses or other costs that they have no or little opportunity to repay; (v) compensation and benefits must comply with local laws relating to minimum wages, overtime hours and other benefits; (vi) the formation of trade unions and powers of collective bargaining should be respected.
3. Risk assessment
As a national firm of accountants, Sumer Group Holdings Limited and its subsidiaries consider the risk of modern slavery within the business to be low, but it acknowledges the risk that a supply chain may involve the use of a hidden or unknown subcontractors who are reliant on forced labour. Procedures are being designed to address this risk.
4. Due diligence processes
Sumer Group Holdings Limited and its subsidiaries have started the process of scoping its procedures to assess its suppliers against the following risk indicators:
- Geographic – the geographical location of supplier, its business operations and/ or its raw materials.
- Product and service – risks associated with specific products and services, such as known worker risks or instances where modern slavery has previously been identified.
- Employment practices – risks associated with specific recruitment and employment practices.
5. Focus in this financial year During 2025 Sumer Group Holdings Limited and its subsidiaries intend to focus on:
- Formalising and rolling out its Modern Slavery policy;
- Reviewing its suppliers, gathering additional information to assist in identifying those which might be considered to be at greater risk of involvement in modern slavery or human trafficking, using the indicators mentioned above;
- Extending its due diligence processes to ensure that suppliers are not in fact engaged in modern slavery or human trafficking; and
- Educating staff about the risk of modern slavery in our business By prioritising its risks in this way, we believe we can target our actions where they are likely to have the most impact.
6. Training and awareness
Sumer Group Holdings Limited and its subsidiaries are in the process of arranging for all its staff to complete appropriate online training modules on modern slavery and human trafficking.
This statement was approved at by the board of Sumer Group Holdings Limited on 23rd January 2025.
Warren Mead
Chief Executive Officer
