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 2018.
The firm is a provider of legal services to individuals, commercial, insurance and public sector clients. The firm has around 1250 people and had a global turnover of around £97 million for the financial year ending 30 April 2018.
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 2018, we continued to prepare to broaden our practice of requiring suppliers to observe a tender process pre-contract and at contract renewal.
In some cases, we have invited prospective suppliers to produce a copy of their own Modern Slavery Policy or at least to confirm that they have implemented such a policy. As part of our updated procurement process, we will formally score a tenderer more highly if they can produce an anti-slavery policy for our review. As noted below, we have appointed a new Contracts Manager who, with input from our Modern Slavery Committee, has assumed central responsibility for implementing this process.
We have also finalised 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.
Since our financial year-end, we have started to present the Model Clauses to suppliers for signature. Whilst we will report further next year with our progress in achieving supplier “buy-in”, early signs are that the task of imposing, and in particular enforcing, such obligations will prove challenging.
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 are pleased to announce that, since the end of our financial year 2017/2018, we have appointed a Contracts Manager, who has embarked on a large scale review of our supplier base.
Aside from tighter control on our supplier spending, we hope to achieve a substantial reduction in the number of our suppliers. This will allow us not only to monitor more carefully our suppliers’ activities, but should also enable us more easily to impose conditions on suppliers who must compete more keenly to win work from us.
We will update our progress in next year’s statement.