Financial Year Ending April 2026
Signed by: Richard Chitty, CEO
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015.
Although Frankham Consultancy Group does not currently meet the statutory turnover threshold requiring publication of a Modern Slavery Statement, the Company has elected to publish this statement voluntarily as part of its commitment to ethical business practice and transparency.
The Board of Directors recognises the importance of preventing modern slavery and human trafficking and is committed to maintaining appropriate governance and oversight of the Company’s approach to managing these risks.
Frankham intends to publish this statement annually within six months of the end of its financial year in line with Government guidance.
This statement has been approved by the Board of Directors and signed by a Director on behalf of the Board.
Our organisation
Frankham Consultancy Group is a UK-based professional consultancy providing multidisciplinary services across the built environment sector, including surveying, engineering, design, and compliance.
The Company operates primarily within the United Kingdom and delivers professional services to public and private sector clients.
Our policies and governance
Frankham operates a Modern Slavery Policy within its Integrated Management System (IMS). The policy reflects a zero-tolerance approach to modern slavery and human trafficking.
The Senior Management Team has overall responsibility for policy oversight. The policy and associated risk position are reviewed at least annually as part of the Company’s IMS review cycle.
Risk assessment
Frankham undertakes a proportionate assessment of modern slavery risk within its operations and supply chain, taking into 1 Risk Assessment
Frankham adopts a proportionate and risk-based approach to modern slavery prevention, reflecting the nature, scale and complexity of its operations as a professional services consultancy. Taking into account:
- The professional nature of its services
- Its UK-based operations
- Workforce profile
- Supply chain structure
Based on this assessment, the risk within Frankham’s directly employed workforce is considered low.
The Company recognises that risk may arise within supply chains. While the majority of Frankham’s suppliers provide professional services within the UK, the Company remains alert to the potential for risk in subcontracted or outsourced services.
Areas of Potential Modern Slavery Risk
Based on its assessment, Frankham considers the risk of modern slavery within its directly employed workforce to be low due to the nature of its professional services, UK employment contracts and right-to-work verification processes.
Potential areas of elevated risk may arise within parts of the wider supply chain that are common across the construction and built environment sector, including:
- construction contractors and labour-intensive subcontractors
- facilities management and site services providers
- cleaning, security and maintenance services
- suppliers operating through agency labour or labour providers
Frankham’s supplier approval and procurement processes seek to identify and mitigate these risks through proportionate due diligence.
Supply Chain Overview
Frankham’s supply chain primarily consists of:
- professional consultancy subcontractors (engineering, surveying, specialist advisors)
- construction contractors engaged on small opening up works to facilitate the performance of our professional services
- professional service providers
- operational support services (IT, facilities management and office services).
The majority of suppliers operate within the United Kingdom and are engaged through formal contractual arrangements.
As part of its Supplier Approval Process, Frankham undertakes proportionate checks on suppliers including verification of legal status, professional competence, relevant insurances and applicable policies.
Due Diligence and Supply Chain Management
Frankham operates a Supplier Approval Process designed to verify supplier legitimacy, legal status and professional competence.
The Company’s standard terms and conditions require compliance with applicable statutory requirements and employment legislation.
Where suppliers operate in sectors or environments that may present elevated risk, additional enquiries may be undertaken where considered proportionate.
Frankham may periodically review and update its supplier due diligence processes as part of its Integrated Management System to ensure they remain appropriate and proportionate.
Frankham does not currently operate formal labour audits or tiered supply-chain monitoring programmes, reflecting the nature and scale of its professional services operations.
Training and awareness
Awareness of modern slavery risks forms part of employee induction and management oversight processes.
Given the Company’s current operating model and risk profile, formal role-specific modern slavery training programmes are not currently implemented. This position is reviewed periodically.
Reporting Concerns
Frankham encourages employees and associated persons to raise concerns regarding unethical practices.
The Company operates a Whistleblowing Policy and does not tolerate retaliation against individuals who report concerns in good faith.
Where appropriate, concerns may be referred to relevant authorities, including the National Referral Mechanism.
Key Performance Indicators
Monitoring Effectiveness: Frankham monitors the effectiveness of its modern slavery controls through a number of internal indicators, including:
- proportion of suppliers risk assessed annually through the Supplier Approval Process
- number of modern slavery concerns raised through whistleblowing or reporting mechanisms
- number of high risk and contractor (opening up) suppliers who have had an annual periodic review of modern slavery compliance documentation
- proportion of employees who have received modern slavery awareness training (refresher and/or induction)
These indicators are reviewed periodically by senior management as part of the Integrated Management System review cycle.
Continuous improvement
Frankham is committed to reviewing its approach to modern slavery risk management annually.
As the business grows and supply chains evolve, the Company will consider whether additional measures are appropriate and proportionate.
Approved by the Board of Directors.