Ethical Transparency

We believe all organisations can positively impact society and create more stable and long-term opportunities for economic growth. In line with our values, Várri Consultancy is making a voluntary modern slavery and human trafficking statement relating to section 54 of the Modern Slavery Act 2015 of the United Kingdom (UK).

We oppose slavery and human trafficking in all forms and voluntarily make this statement to set out the steps we have taken to ensure no slavery or human trafficking in our business or supply chains. This statement covers our direct operations and supply chains.

About Us

Our Business

Várri Consultancy is a modern, independent management consulting boutique specialising in strategy, risk, and governance advisory services. We focus on economic, societal, and environmental sustainability to create more stable and long-term growth opportunities for all stakeholders. It is risk management with a conscience.

Our Company Structure

Várri Consultancy is a sole establishment registered in Dubai, United Arab Emirates (UAE), and is directly owned by the founder, Johnny Kollin. It has no subsidiaries, associates, or parent company.

Our People

We had one permanent employee, a foreign national, apart from the founder as of 31 December 2021.

Until recently, there has been no national minimum salary for expatriate employees in the UAE other than for domestic workers from certain countries. Article 27 (Minimum Wage) of the new UAE labour law, which came into force on 2 February 2022, introduced a mechanism whereby the UAE “Cabinet may, upon the proposal of the Minister and in coordination with concerned authorities, issue a resolution to determine the minimum wage for workers or any category thereof.” As of the date of this statement, no such resolution regarding a minimum wage level has been issued.

There are also specific salary thresholds and requirements for UAE nationals, depending on their education level. We had no UAE nationals employed as of 31 December 2021.

Várri Consultancy is committed to paying salaries that exceed the minimum wage for UAE nationals and expatriates, respectively, and the UAE Living Wage (as set out by the Wage Indicator Foundation), whichever is higher.

Our Supply Chain

Around 39% of our third-party expenses (excluding salaries) are sourced from suppliers based in the UAE, with the remainder coming from the US (38%), the EU (18%), the UK (4%), and ROW (1%). Our supply base is concentrated in numbers, with the top 10 suppliers accounting for 74% of total expenses. Nonetheless, they are diverse across scale, ownership type, and structure – from one-person companies to publicly listed multinational corporations.

Those suppliers with whom we transact directly, our so-called tier-1 suppliers, include mainly the following:

• Professional and administrative services: This category includes, for example, suppliers that provide company formation services, employment and visa services, and co-working services, which are primarily based in UAE. It also includes project-based contracts with a UAE entity that is part of a global law firm network and PR and creative agencies in the EU, the UAE, the United Kingdom, and the United States, which accounted for 52% of our total expenses. One of the creative agencies is a self-employed entrepreneur working from home, with no other permanent employees. The other two creative agencies are small enterprises where the partners and full-time employees carry out all Várri Consultancy work.

• Information technology (IT), information service providers, and software as a service (SaaS) companies: These suppliers are located primarily in the United States and the European Union. Together. Together, they accounted for 30% of our total accrued expenses in the fiscal year ended 31 December 2021 (FYE2021). Suppliers range from privately owned software-as-a-service (SaaS) companies to global publicly listed corporations such as Microsoft. We usually source these services under subscription contracts running from one to twelve months in length.

• Insurance companies and third-party providers: As of 31 December 2021, this includes annual contracts with three UAE-based insurers, which together accounted for 4% of our total accrued expenses.

• Other suppliers: These are primarily located in the UAE, UK and US, which accounted for 14% of our total expenses. These are typically transactional with short-term or intermittent relationships.

We have low visibility on Tier 2 suppliers.

Our Clients

Our clients in 2021 included privately-owned corporate entities based in UAE. Our prospective clients also include financial institutions and government-related entities.

While we are open to acting globally, our current focus is on the UAE and the wider Gulf Cooperation Council (GCC) region.

Our Policies on Modern Slavery and Human Trafficking

There is no specific legislation dealing with modern slavery in the GCC region. You can find more information about the laws and initiatives of the Government of the UAE for combatting human trafficking here.

We are not required to make a modern slavery statement under section 54 of the Modern Slavery Act 2015, as our annual turnover is less than GBP36 million. Nonetheless, we are making this voluntary statement to show our commitment to ethical trading principles and to set out the steps we are taking to tackle modern slavery and human trafficking in our business and supply chains.

We are committed to ethical trading principles and acquiring goods and services without harm to others. Our Anti-Slavery and Human Trafficking Policy, adopted in 2021, reflects our commitment to acting ethically and with integrity in all our business relationships. The policy also seeks to implement and enforce effective systems and controls to ensure slavery and human trafficking are not happening anywhere in our supply chains.

We have outlined below our key considerations and policies concerning our suppliers and clients.

Suppliers and Clients

Várri Consultancy is committed to understanding and addressing the modern slavery risks we are exposed to through our supplier relationship. We assess our supply chain for modern slavery risks, considering factors such as country risk, sector, category risk, spending, and the likelihood of modern slavery. We utilise data and analysis from third-party expert organisations such as the International Labour Organisation and Global Slavery Index.

We include anti-slavery and human tracking provisions in written contracts with all material suppliers to the extent possible. We currently do not employ any agency workers. If we do so in the future, our policy is to only use agency workers through reputable employment agencies that adhere to our anti-slavery and human trafficking policy (or equivalent policies).

We have processes for conducting general due diligence on counterparties before establishing a client relationship and include anti-slavery and human tracking provisions in all our client contracts.

As a young business, we intend to develop further our policies and procedures in line with the growth of our operations. We want to establish a human rights due diligence process to identify, prevent, mitigate, and account for how we address actual and potential adverse human rights impacts from our operations, supply chain, and other relationships. We may either develop such a process alone or in collaboration with others.

Risk Assessment, Prevention, and Mitigation

The main locations of our Tier 1 suppliers include UAE, the UK, and the US. On the client-side, 99% of our revenue in 2021 was generated from clients in the UAE, with the remaining 1% coming from clients in the US and EU.

The UK had a weighted average modern slavery vulnerability score of 11.1, making it the 16th least vulnerable country out of 167 countries assessed in the Global Slavery Index 2018. The US scored 15.9, making it the 22nd least vulnerable country out of 167 countries evaluated in the Global Slavery Index 2018. UAE scored 26.8, placing it as the  35th least vulnerable country out of 167 countries assessed in the Global Slavery Index 2018. The UK and US have “BBB” government response ratings and were in the top 3 globally, while UAE had a “B” rating.

The Global Rights Index assesses the degree of respect for workers’ rights in 139 countries, summarised in a rating on a scale from 1-5. A rating of one means that violations of workers’ rights are rare in the country, while five means that workers’ rights are absent.

Effectiveness in Combating Modern Slavery and Human Trafficking

We use the following key performance indicators (KPIs) to measure how effective we have been at ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains:

• The number of reported breaches in the past year.

• Percentage of staff who are trained on identifying and addressing the risk of slavery and human trafficking in our business and supply chains.

Training

We intend to train any staff hired in 2022 to ensure a solid understanding of modern slavery and human trafficking risks in our supply chains and business. Over the medium term, we will also consider requiring our business partners to offer their staff, suppliers, and providers training.

About this Statement

This voluntary slavery- and human trafficking statement is made in connection with section 54(1) of the Modern Slavery Act 2015 for the financial year ending 31 December 2021. The sole owner approved it on 24 June 2022.