Modern Slavery & Human Trafficking Policy and Statement for Financial Year ending 31st December 2018


This document contains Hardy Fisher’s policy on modern slavery and human trafficking and its statement under section 54 of the Modern Slavery Act 2015.

Privacy Notice

Forced or compulsory labour, human trafficking and other kinds of slavery represent some of the gravest forms of human rights abuse in any society. We all have a responsibility to be alert to the risks in both the Hardy Fisher business and our supply chain.

Hardy Fisher is committed to conducting all aspects of its business in an ethical and transparent manner. We acknowledge and are committed to our duties and responsibilities under the Act.

Hardy Fisher values require that all workers are treated with dignity and respect. We are fundamentally opposed to slavery, human trafficking, forced labour, debt bondage, the sale or exploitation of children and all exploitative practices in the workplace.

Hardy Fisher requires that all contractors and suppliers do not engage in any such practices, and do not knowingly themselves contract with third parties which do.

Hardy Fisher values require that it terminates business relations and reports to the respective authorities any contractor or supplier found to be in breach of anti-slavery and human trafficking obligations.

Modern slavery statement

This statement sets out the approach that Hardy Fisher ltd have either already taken during the financial year to 31 December 2018, or intend to take during the current financial year, to prevent modern slavery and human trafficking in its business and supply chains.

We are seeking to apply the policies and procedures detailed in this statement across relevant parts of the business but acknowledge it may take time to achieve consistent standards, especially overseas and within our supply chains.

Our business

Hardy Fisher is a dynamic international business and IT consulting company with expertise in business and technology strategy and delivery, organisational transformation, private equity, venture capital and business incubation. Our people specialise in delivering innovative and commercial, solutions to business and technology challenges. In Diverse Company is also a trading name of Hardy Fisher Ltd., In Diverse Company partners with businesses who want to accelerate their commercial success. Using a unique methodology and incorporating data science and human expertise, data is analysed from the past, to make recommendations for the future, ensuring there is focus on D&I in its broadest sense. In Diverse Company helps clients make decisions that will impact significantly, and measurably, on their business performance. Services include D&I ROI, an audit of what is currently going on in an organisation, and what their future may look like, this includes gaining data insights from employee data, assessments and surveys, interviews and focus groups, D&I solutions including coaching, leadership development, and other workshops. Support can also be provided in strategy development and consultancy.

Hardy Fisher employee overview

We have a growing team predominantly based in the UK but operating internationally with a diverse client base across the public and private sectors. We are committed to providing an inspiring and rewarding place to work and this is at the heart of our business strategy. We comply with all relevant local minimum age and wage laws and do not employ child labour.

All our employees are:

  • paid by bank transfer; we do not allow payment to be made into third party bank accounts, thus minimising the risk of forced or compulsory labour; and
  • vetted for the right to work in the country where they are employed. Where employees require a work permit/VISA we ensure they have the necessary documentation in place.

As a responsible employer, we take the welfare of our employees seriously. Our whistleblowing policy encourages employees to report wrongdoing (including exploitation) in any form.

Supply chain overview

Hardy Fisher may outsource operating areas such as IT development, Finance, Legal, Creative and some international business development as well as other ad-hoc non-core business and our business model means that on large programmes we may work with several contractors, sub-contractors and other suppliers to fulfil our commercial and contractual obligations to our customers.

In common with many other businesses operating in our industry, depending on the size and scale of the projects we are involved in our supply chain can potentially be complex; there are sometimes multiple tiers of suppliers between Hardy Fisher (as the main contractor) and the source of the materials and labour we use.

We are aware that the biggest slavery and human trafficking risks for Hardy Fisher lie in our supply chains, particularly the supply chains of our sub-contractors in higher risk jurisdictions and we monitor and review our processes with all our suppliers to ensure we mitigate risk wherever possible.


We provide training to our staff in order to ensure a sound comprehension of the risks within our business, our clients and supply chains of modern slavery and human trafficking.

Ongoing review

We will continue to review and evolve our modern slavery and human trafficking policies and procedures over time.

Failure to comply

A failure to comply with the Act, and/or this policy statement will be deemed to be a material breach of the terms of our standard commercial agreements and contracts of employment.

This statement is made pursuant to Section 54(1) of the Act and constitutes Hardy Fisher Ltd’s Modern slavery and human trafficking statement.

Approved by Jason Beresford Managing Director

For and on behalf of In Diverse Company (a trading name of Hardy Fisher Ltd.)

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