This statement is pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for fiscal year ending 30 April 2022.
In this statement use of the term “modern slavery” is intended to reference the term “slavery and human trafficking” used in section 54 of the Modern Slavery Act 2015 and includes reference to (without limitation) slavery, servitude, forced or compulsory labour, exploitation of children and human trafficking.
Weightmans has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners.
We operate systems as part of our procurement processes to seek to identify, assess and monitor potential risk areas in our supply chains; to mitigate the risk of slavery and human trafficking occurring in our supply chain and to protect whistle-blowers.
The firm is a provider of legal services to individuals, commercial, insurance and public sector clients. The firm operates in England and Scotland as a limited liability partnership incorporated in England together with an affiliate limited liability partnership under common ownership, incorporated in Scotland, and on 30 April 2022 had a headcount of around 1300 people, including members and employees.
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.
To seek to ensure that all parts of our business and supply chains are free of modern slavery, 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. The team includes our General Counsel, Legal Counsel, Contracts Manager, Environmental, Social and Governance Manager, and Head of HR, together with representatives from our audit and compliance team and HR. The Modern Slavery Team meets quarterly and reports to the firm’s executive management board (“Board”), ensuring that decisions required rest with those at the highest tier within the business.
We require our suppliers to observe a tender process pre-contract and at contract renewal. Our Contracts Manager, supported by a Compliance Assistant and our in-house Legal Counsel, oversees a process of due diligence undertaken with new and existing suppliers to seek to ensure that each supplier meets our standard contractual requirements.
As part of our procurement process and general risk assessment, we give positive weight to those suppliers who have an anti-slavery policy for our review. To aid us in carrying out a risk assessment on each prospective supplier we have adopted a supplier management tool which assists in automatically scoring supplier responses and highlighting areas of concern based on the supplier’s responses to our pre-contract enquiries. Where areas of concern are identified we seek to work with the prospective supplier to help them provide further evidence with the aim to help alleviate the concerns and rectify any non-conformance prior to the relationship proceeding.
Over the coming 12 months, we intend to introduce proportionate measurable key performance indicators for suppliers to assist with contact management around compliance with the required supplier’s commitments to help prevent modern slavery.
All prospective suppliers must sign up to our supplier management code of conduct and supplemental clauses (“Model Clauses”). Our Model Clauses impose obligations on suppliers consistent with our policies and commitment including in respect of our approach around modern slavery. The Model Clauses often supplement the suppliers’ own terms and conditions. The Model Clauses include obligations on the supplier:
- not to engage in slavery or human trafficking;
- to comply with the Modern Slavery Act 2015;
- (where applicable) to comply with its own Modern Slavery Policy and Modern Slavery Statement;
- 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 an explanation of the action taken in response to a breach, will inform our decision to renew the supply contract.
During the 12 months to 30 April 2022, we have not received any notifications of breach or incidence of Modern Slavery. In addition, we have sought to apply greater rigour to seek to achieve full compliance with our policies and procedures by undertaking an internal audit of our suppliers to ensure that all suppliers are subject to the due diligence process with any non-conformance challenged with the supplier. A rolling audit programme of suppliers is in operation.
We are a supplier of services to our clients, many of which require sight of our own Modern Slavery Policy as a condition of contract award/renewal.
Clients have imposed on us modern slavery obligations like those that we are seeking to impose on our own suppliers.
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.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide annual training to our staff.
Approved by the members of Weightmans LLP acting by the Board under delegated authority on 26 October 2022.
Designated Member and Managing Partner
For and on behalf of Weightmans LLP