Modern slavery and human trafficking statement

We are committed to ethical practice in all of our business dealings and are taking steps to prevent modern slavery and human trafficking in our business and our supply chains.

We make the following statement in support of that aim and also in compliance with section 54(1) of the Modern Slavery Act 2015 (the Act).

This statement is for our financial year ending 5 April 2016.

About us

Follow this link for information about us: /about-us

Gillian Rivers, a family law partner, is co-chair of the International Bar Association’s Task Force against Human Trafficking and an invited member of the Santa Marta Group, which is an alliance between police forces around the world, the Home Office and the Roman Catholic Church. The aim of both associations is to combat human trafficking and modern slavery, raise awareness of the problem and support victims.

Our people

We have 613 people working with us made up of partners, employed lawyers, employed support staff and administrative staff provided to us by third parties.

Our employees enjoy all of the statutory employment rights to which they are entitled and our human resources department ensures our employees have the legal right to work in the UK. Employees are provided with safe working conditions and treated with dignity and respect.

Our suppliers

Since the Modern Slavery Act 2015 came into force, we have made it our policy to include compliance with the Act as a term of our supply contracts.

For existing supply contracts, we have sent our major existing suppliers a questionnaire seeking assurances that their business is free from modern slavery. We are in the process of assessing those responses.

Where responses are inadequate, steps will be taken to obtain further information.  Where responses suggest a supplier has engaged in modern slavery or human trafficking, our risk and compliance team (risk) will take suitable action, including reporting where appropriate. 

This supplier assessment process will be conducted regularly by risk.

More in-depth enquiries have been made of our supplier of administration staff on the basis that, as a supplier of people, it poses an increased modern slavery risk.

High-risk activities

We do not consider our business activities to pose a high risk of modern slavery. In terms of our supply chain, we consider the risk factors to be territory and whether they are a significant supplier of people.

At these early stages we have concentrated our modern slavery enquiries on our external suppliers of people.

Training

Risk conducts a face to face induction for new employees which will now include an outline of our modern slavery prevention objectives. New employees and partners will be told that they should report any concerns about the treatment of others to risk or any concerns about their own situation to either human resources or risk.

Our whistleblowing policy now promotes the reporting of modern slavery concerns and provides protection for any employees that do so.  New employees will be informed of the policy at their induction.  Existing employees will be informed of the changes to the policy by the end of 2016.

Those involved in the recruitment of our employees will be given specific guidance on the terms of the Act.  In particular, human resources will be informed that any allegation of staff being treated without dignity or respect or that working conditions have been made unsafe must be treated with the utmost seriousness. We aim to deliver this training by the end of February 2017. 

Those involved in procurement will be given specific guidance on the Act so that appropriate assurances can be sought from potential suppliers and appropriate terms included in supplier contracts.   This guidance will be delivered as part of a larger review of our procurement processes which we aim to complete by the end of June 2017.

Responsibility

We take compliance with law and regulation seriously and have a dedicated risk team for that purpose.  Tim Palmer is the partner responsible for the firm’s risk management and compliance and our Compliance Officer for the purposes of our regulator. He and his team are responsible for monitoring the firm’s compliance with law and regulation and are also responsible for reporting to external authorities where appropriate. To achieve this, risk promotes a culture where all staff are welcome to report anything that concerns them.   

Risk will be responsible for monitoring compliance with the Act and, where external reporting is necessary, that will be undertaken by risk.

The policies and procedures adopted by this firm to achieve compliance with the Act, as detailed above are:

  • recruitment procedures to ensure we do not engage in or procure slavery, servitude or human trafficking 
  • guidance to ensure those who recruit on behalf of this firm are aware of these obligations
  • training to ensure all employees are aware that they may and should report any modern slavery concerns to risk
  • protection for employees making such reports in the form of a whistleblowing policy which makes direct reference to the Act
  • procurement procedures that require our suppliers to comply with the Act
  • checks on existing suppliers aimed at detecting slavery, servitude or human trafficking in our supply chain. Such checks to be overseen by risk so that appropriate action may be taken, including external reporting if necessary.

Risk will be responsible for reviewing whether these policies are achieving the aims of the Act and developing further policies, training and guidance where necessary. 

Board approval

This statement has been approved by the firm’s management board, who will review and update it annually.

Penningtons Manches LLP

Penningtons Manches LLP is a limited liability partnership registered in England and Wales with registered number OC311575 and is authorised and regulated by the Solicitors Regulation Authority. San Francisco is an associated office.

Penningtons Manches LLP