GLG Modern Slavery Act Statement
Fiscal Year 2023: January 1, 2023 – December 31, 2023
We strive to ensure that modern slavery or human trafficking does not support our business. This objective is explicit in our relevant policies and our approach to human rights.
This statement is made pursuant to section 54 of the United Kingdom’s Modern Slavery Act 2015 (the “Act”) with respect to the financial year ending 31 December 2023 and sets out the approach Gerson Lehrman Group has in place to prevent the occurrence of modern slavery and human trafficking in our supply chain or in any of our business operations providing services in the United Kingdom and elsewhere. The Republic of Ireland has similar legislation, primarily the Criminal Law (Human Trafficking) Act 2008, as amended by the Criminal Law (Human Trafficking) (Amendment) Act 2013.
The affiliated entities Gerson Lehrman Group (Ireland) Limited which is incorporated in Ireland and Gerson Lehrman Group Limited which is incorporated in England have international affiliates globally (together “GLG”). GLG is subject to the Act as it is providing services within the UK and has a consolidated global turnover above the required threshold.
GLG is a professional teaching and learning platform connecting business to subject matter experts. GLG employs over 2,500 people in offices globally. GLG is committed to acting professionally and with integrity in all its business dealings and relationships whether in the UK, Ireland or abroad. GLG partners with a variety of small to medium size suppliers for the majority of its local requirements and with multi-national suppliers for items such as technology infrastructure and real estate. GLG has never been made aware of any activities involving either itself or its supply chain that would give concern in relation to slavery or human trafficking. In the event that any such incident were highlighted to GLG, we would promptly take action in accordance with our legal and moral obligations.
We consider the risk of modern slavery or human trafficking existing within our business or supply chains to be relatively low. GLG operates a number of policies which reflect our objective to act in an honest and ethical manner, and to comply with all applicable legislation with regards to our employees, clients and our business relationships. We strive to ensure that neither modern slavery nor human trafficking supports our supply chain or our businesses. We aim for a zero-tolerance approach to violations of anti-slavery and human trafficking laws.
GLG maintains robust recruitment policies, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will. The organisation uses its internal recruiters to source labour and on the rare occasion when it uses an external agency it always verifies the practices of any new agency it is using before accepting workers from that agency.
GLG maintains whistleblower and anti-retaliation policies so that all employees know they can raise concerns about our practices, including our compliance with laws, without fear of reprisal. GLG also maintains an anonymous hotline available globally. Any concerns, policy violations or violations of law may be raised on an anonymous basis on these hotlines. During the financial year ended 31/12/2022 the Compliance Team of GLG has not received any reports which relate to knowledge or suspicion of slavery or human trafficking.
GLG evaluates its clients and vendors to identify high risk clients/vendors posing the greatest risk to compliance with the law. GLG’s contracts with clients and vendors require compliance with all applicable laws. GLG employees, suppliers, vendors, contractors and any other party with whom GLG conducts business are not permitted to engage in any activity constituting forced labor, slavery or human trafficking.
GLG will review the continuation of business with individuals and organisations found to be involved in slavery, human trafficking, forced or child labour and retains the right to cease business with such individuals and organisations on this basis.
GLG is able to monitor the success of its anti-slavery policy by strictly enforcing the terms of its agreements with suppliers and partners.