This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for financial year ending 30 April 2020.
The firm is a provider of legal services to individuals, commercial, insurance and public sector clients. The firm has around 1285 people and had a global turnover of around £103 million for the financial year ending 30 April 2020.
The firm has offices in England and Scotland only.
Our policies on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
In light of the obligations to report on measures to ensure that all parts of our business and supply chains are slavery free, we have put in place a designated Modern Slavery Policy. This complements our Business Ethics Policy and our Whistleblowing Policy, both of which further demonstrate our stance on unethical and inappropriate behaviour.
Our Modern Slavery Act team
Our Modern Slavery Policy and other policies referred to above, demonstrate our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains or within our own business.
We have established a team to oversee the firm’s activities towards the implementation and enforcement of our Modern Slavery Policy. Our team reports to the firm’s Board periodically, to ensure that decisions required are taken at the highest tier within the business.
During financial year ended 30 April 2020, we have maintained our practice of requiring suppliers to observe a tender process pre-contract and at contract renewal. During the past year, we have grown our team with the recruitment of a Compliance Assistant providing support to our Contracts Manager in ensuring all our new suppliers undergo this process.
We invite prospective suppliers to confirm that they have implemented such a policy by signing up to our supplier management code of conduct and supplemental clauses. As part of our updated procurement process, we give positive weight to those suppliers who have an anti-slavery policy for our review. We are currently in the process of rolling out a supplier management tool which will automatically score supplier responses and highlight areas of concern. These areas will be flagged as non-conformances and suppliers invited to provide more evidence with the aim to alleviate areas of concern.
Suppliers continue to be invited to sign our “Model Clauses” which, where accepted, impose obligations on suppliers which supplement (and sit alongside) those contained in suppliers’ own terms of supply. These clauses include obligations on the supplier:
- to comply with the Modern Slavery Act 2015 and its own Modern Slavery Policy;
- to warrant that none of its personnel has engaged in any modern slavery offence;
- to the extent commercially practicable, to require that its own suppliers do not engage in slavery or human trafficking; and
- to notify us of any breach of the above.
A failure to comply entitles us to terminate the contract unless the supplier satisfies us that it has taken steps to avoid a re-occurrence of the breach. A notification of breach and, in particular, an explanation of the action taken in response to a breach, will inform our decision to renew the supply contract.
During the past year we have not received any notifications of breach or incidence of modern slavery.
This financial year, we’ve continued with our project to have our suppliers sign up to our model clauses and have seen a significant improvement on last year. The task of imposing such obligations continues to prove challenging, however.
We are, of course, ourselves a supplier to many clients, a number of whom have requested sight of our own Modern Slavery Policy as a condition of contract award/renewal.
Some clients have imposed on us modern slavery obligations similar to those that we are seeking to impose on our own suppliers, as discussed above.
Compliance with such obligations is challenging, at least to the extent that they require us to influence the behaviour of our own suppliers. We view this however as an additional incentive to impose the Model Clauses and, in the face of breach, to terminate supply arrangements where it is commercially practicable for us to do so.
We will update our progress in next year’s statement.