Modern Slavery Statement

This statement constitutes the modern slavery and human trafficking statement of BDO Ireland for the financial year ending 28/02/2025. 


The United Kingdon’s Modern Slavery Act 2015 (‘The Act’) requires all bodies corporate and partnerships who (irrespective of where they are incorporated) carry on a business, or part of a business, in the UK supplying goods or services, and have a consolidated global turnover of above £36 million (or Euro equivalent) per annum, prepare and publish an annual “Slavery and Human Trafficking Statement”. Corresponding legislation in Ireland includes the Criminal Law (Human Trafficking) Act 2008, as amended by the Criminal Law (Human Trafficking) (Amendment) Act 2013. 

This statement sets out the measures we have taken during our financial year to ensure that slavery or human trafficking is not taking place within our organisation and our supply chain. It also details any steps we intend to take in the coming years. 

 

What is Modern Slavery?  

Modern slavery is a serious crime that encompasses various forms of exploitation, including forced labour, human trafficking, debt bondage, and sexual exploitation. Sadly, it affects individuals of all ages, genders, and ethnicities, and is likely present in all nations across the globe. 

Human trafficking involves the trade and exploitation of individuals for financial gain. It is a global issue that is defined by the UN Trafficking in Persons Protocol as the recruitment, transportation, transfer, harbouring, or receipt of a person through force, coercion, abduction, fraud, or deception for the purpose of exploitation. 

Modern slavery generates enormous profits every year, which highlights the need for urgent action to combat this issue, particularly in developed countries where a significant portion of these profits are being generated.  

 

Organisational Structure  

BDO Ireland is a member of BDO International Limited, a UK company limited by guarantee, and forms part of the international BDO network of independent public accounting, tax and advisory Firms which perform professional services under the name and style of BDO. Each of BDO International Limited and the individual member firms is a separate legal entity and has no liability for another such entity’s acts or omissions.  

The Irish Firm of BDO consists of a group of Irish registered partnerships formed under the Partnership Act 1890 which are wholly owned by the partners in the Firm and at 1 March 2025 there were 40 partners. 

BDO is the brand name for the BDO network and for each of the BDO Member Firms. 

Further details on our governance structure can be found in our annual transparency report which is available on our website. 

 

Our Policies 

We believe businesses have an economic imperative and an ethical responsibility to do what they can to ensure a thriving, sustainable and equitable world. We believe that how we behave as a business is intrinsically linked to the societal and environmental impact we have. Most importantly, we believe in doing the right thing. 

BDO Ireland is committed to ensuring that our business operations are conducted in a manner that is honest, ethical, and compliant with all relevant laws. We recognise the importance of preventing modern slavery and human trafficking in our supply chain and within our organisation. 

To achieve this objective, we have a dedicated Modern Slavery Policy, and we have a zero-tolerance approach towards any violations of anti-slavery and human trafficking laws.  

We review this policy, at minimum, on an annual basis to ensure that it is appropriate and is being properly applied and it will be updated where necessary. 

 

Related Policies 

We also have a number of further BDO Ireland policies and documents which reflect our objective to act ethically and in line with our legal and regulatory obligations with regard to our employees, clients and our business: 

  • Transparency Report
  • Ethics and Independence Manual
  • BDO Staff Handbook
  • Various office specific Money Laundering, Terrorist Financing, and Proliferation (MLTFPF) Compliance Manuals
  • Anti-Bribery and Corruption Policy

 

Reporting knowledge or suspicion of slavery or human trafficking 

Our Modern Slavery Policy requires that all employees and partners within the firm report any knowledge or suspicion of slavery or human trafficking immediately. If an individual becomes aware of, or has concerns regarding, such activities, they are advised to inform the relevant Engagement Partner, the Head of HR, the Chair of the Quality & Risk Committee or the Firm’s Managing Partner as the individual see fit. These individuals will then determine what further action, if any, should be taken. 

In addition to our Modern Slavery Policy, we have clear reporting mechanisms for partners, employees, contractors, agency staff, clients and suppliers to report on any matters of concern, including any suspicions they may have related to modern slavery and human trafficking. Our Protected Disclosure Policy aims to encourage and enable individuals to report concerns about unethical, illegal, or improper conduct in a safe and confidential way, without fear of retaliation. Reports can be made anonymously through the Firm’s “Protected Disclosures” accessible through the Firm’s website. 

If the reported issue also involves money laundering or terrorist financing, an additional report must be made to the firm's Money Laundering Reporting Officer (MLRO) as per the Firm’s Anti-Money Laundering Policies and Procedures Manual. 

The Firm’s Protected Disclosures policy is highlighted to employees and partners on a reoccurring basis through refresher training. This policy facilitates and encourages employees and partners to raise concerns or disclose information which relates to wrongdoing, illegal practices or unethical conduct, which may come to their attention through work (including concerns that may relate to modern slavery and human trafficking). This includes the facility for anonymous reporting. 

It is important to note that these reporting obligations do not replace any legal requirements for reporting or disclosure. If there are existing statutory reporting requirements and procedures, they must be fully followed. 

 

Training 

We want to help our employees, partners, principals, clients and suppliers to understand more about these issues and understand how to report any suspicions they may have related to modern slavery and human trafficking.  

As part of this process, we have created a mandatory internal eLearn which all partners and employees will be required to complete every year, beginning January 2026.  

We continue to consider, on an ongoing basis, ways to further enhance awareness on the issues of slavery and human trafficking and of our Anti-Slavery and Human Trafficking Policy among relevant employees, partners and principals. 

 

Clients 

While most of our clients are based in low-risk countries for modern slavery, our client acceptance and ongoing monitoring procedures feature detailed risk assessments, including anti-money laundering checks, background screening, sanctions evaluation, business interests review, management and litigation history, regulatory status, and conflict of interest analysis.  
These measures ensure regulatory compliance, risk mitigation, and uphold our commitment to ethical standards in client onboarding and ongoing relationships. 

 

Employment Procedures  

BDO Ireland has procedures in place pertaining to our employment practices. 

  • Robust recruitment processes in line with Republic of Ireland employment law, including “right to work” document checks, contracts of employment, and checks to ensure all employees are above minimum working age.
  • As part of our onboarding process, HR requires a copy of the new employee’s passport, professional qualification and visa documents, where applicable. All documents retained by BDO are held on file as soft copies and BDO do not request or hold original copies of an applicant’s identity, visa, passports or other official documents. Any original copies of such documentation received by BDO are immediately returned to the applicant and all data held by BDO is stored and held on file in line with the current legislation.
  • Our procedure for prohibiting the use of recruiters or labour brokers, including child labour, who do not comply with the local labour laws of the country in which recruiting occurs is documented within our Recruitment and Selection Policy.
  • Our procedure to ensure workers, including those hired by recruiters, are provided with detailed and accurate work agreements or similar work papers, prior to relocation, in cases where the worker must relocate to perform the work, and in a language understood by the worker is documented within our Relocation Document.
  • Market-related pay and reward, which is reviewed annually and linked to professional services firms benchmarks.

 

Supply Chain and Procurement 

While it is true that BDO Ireland and the majority of our suppliers are not in industries with a high risk of modern slavery, we understand the importance of remaining vigilant in our efforts to combat slavery and human trafficking. We acknowledge that even in countries with lower risk, these issues can still exist, and we are committed to taking appropriate measures to mitigate these risks. 

It is important to note that the majority of our suppliers are located in countries such as Ireland, the UK, and other countries with low prevalence of modern slavery, strong government responses, and low vulnerability to modern slavery, as indicated by the Global Slavery Index 2023. This provides us with some assurance, but we remain diligent in conducting due diligence and monitoring our supply chains to ensure compliance with our standards and applicable laws. 

We recognise that our supply chains extend beyond Ireland and are aware that some of these territories may have a higher risk of modern slavery and human trafficking. However, we will strive to work with suppliers who share our commitment to ethical practices and who have robust policies in place to prevent and address these issues. 

 

Planned Future Actions 

As part of our commitment to preventing modern slavery and human trafficking within our own operations and our supply chain, we intend to: 

  • Provide comprehensive training to all new staff members during their induction process and to all existing staff members through our recently developed eLearn. This training includes information and reporting processes on modern slavery, human trafficking, and our Anti-Slavery and Human Trafficking Policy.
  • Communicate updates to our Anti-Slavery and Human Trafficking Policy to all staff members. This ensures that they are kept informed about any changes or improvements to the policy.
  • Explore ways to further enhance awareness on the issues of slavery and human trafficking among relevant employees and partners. This may include awareness campaigns, workshops, or other initiatives aimed at educating and engaging our stakeholders on these important topics.
  • We are in the process of implementing a Supplier Code of Conduct and Procurement Policy which we hope to have in place by 2026.

We are committed to continuously improving our efforts to address the risks of modern slavery and human trafficking within our supply chain. As we move forward, our approach to mitigating these risks will evolve, and we will adapt our provisions accordingly. 

BDO Ireland takes full responsibility for this statement and its objectives. We understand the importance of regularly reviewing and updating this statement as necessary to ensure its continued relevance and effectiveness.