We make the following statement in compliance with section 54(1) of the Modern Slavery Act 2015 (the Act).
This statement is for our financial year ending 5 April 2017.
We are committed to practices that respect human rights in all of our business dealings.
Gillian Rivers, a family law partner at Penningtons Manches, is a panel advisor to Kevin Hyland OBE, the Independent Anti-Slavery Commissioner, who is leading efforts to tackle modern slavery and human trafficking in the UK and is driving crucial improvement across the anti-slavery response internationally. Gillian is also a member of and honorary legal advisor to the Santa Marta Group, an alliance between police forces around the world, the Home Office and the Roman Catholic Church aiming to combat human trafficking and modern slavery.
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We have 662 people working with us made up of partners, employed lawyers, employed support staff and administrative staff provided to us by third parties.
All of our employees receive the statutory employment rights to which they are entitled and our human resources department ensures all of our employees have the legal right to work in the UK. All of our employees are provided with safe working conditions and we have the expectation that they will be treated with dignity and respect. Our recent wellbeing initiative promotes the importance of wellbeing both at home and in the workplace, providing access to tools, information and support networks to improve mental, physical and financial wellbeing.
We sent our major existing suppliers a questionnaire seeking written assurances that their business is free from modern slavery. The responses indicate that our suppliers understand and respect their obligations under the Act.
We sought particular assurance from the external supplier of our administration staff and, as a result, are content that the administration staff working on our premises and on our behalf enjoy appropriate statutory employment rights, that their right to work in the UK is confirmed, that those involved in their recruitment are trained on the requirements of the Act and that contracts with third party suppliers include appropriate provisions relating to the Act. We have also been provided with evidence that the Act has been drawn to the attention of all staff working for that supplier and that their whistleblowing policy expressly refers to the Act.
In terms of future suppliers, we are now in the process of rolling out our new procurement process. This will centralise procurement to ensure greater scrutiny and better management of supplier relationships. This process has been designed with involvement from members of our Diversity and Inclusion Committee for whom ethical practice and social responsibility are key.
The new process will require all suppliers to meet minimum standards, including compliance with section 54 of the Act. In addition, for certain suppliers, our tender process is designed to prefer those who have Living Wage Foundation accreditation or other accreditations that demonstrate a commitment to ethical practices.
Account audits conducted each quarter will check that suppliers over a spend threshold have been engaged in compliance with the procurement process.
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 territorial and whether they are a significant supplier of people.
We conduct a face to face induction for new employees which includes an outline of our modern slavery prevention objectives. Staff are told that they should report any concerns about the treatment of others to the risk and compliance team and any concerns about their own situation to either that team or human resources.
In addition, we have approved a video course that sets out the impact of modern slavery and the part we all play in its prevention. We aim to ensure that all current and incoming staff will complete this course within the next 12 months.
Our whistleblowing policy promotes the reporting of modern slavery concerns and provides protection for any employees that do so. Employees are informed of the policy at induction and the policy is accessible to staff at any time via our intranet.
We take compliance with law and regulation seriously and have a dedicated risk and compliance 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, the team promotes a culture where all staff are able to report anything that concerns them.
The risk and compliance team will be responsible for monitoring compliance with section 54 of the Act and, where external reporting is necessary, that will be undertaken by that team.
The policies and procedures adopted by this firm to achieve compliance with section 54 of the Act, as detailed above are:
The risk and compliance team will be responsible for reviewing whether these policies are achieving the aims of section 54 of the Act and developing further policies, training and guidance where necessary.
This statement has been approved by the firm’s management board, who will review and update it annually.