Modern slavery and human trafficking statement

We make the statement below in compliance with section 54(1) of the Modern Slavery Act 2015 (the Act).

This statement is for our financial year ending 31 March 2018.

About us

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

Our people

We are committed to practices that respect human rights in all of our business dealings.   

We have 734 people working with us made up of self-employed partners, employed lawyers, employed support staff and administrative staff contracted by us from 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. Our employees are provided with safe working conditions and we have the expectation that they will be treated at all times with dignity and respect.

We are committed to fair employment practices and are pursuing accreditation as a Living Wage Employer.

Our ongoing wellbeing programme promotes the importance of welfare both at home and in the workplace, providing access to tools, information and support networks to improve the mental, physical and financial wellbeing of our staff.

Our suppliers

We are currently centralising our procurement process to ensure supplier relationships are scrutinised and managed effectively. The process was designed with involvement from members of our Diversity and Inclusion Committee for whom ethical practice and social responsibility are key.

All our suppliers are required to meet minimum standards, including compliance with section 54 of the Act. In addition, in certain areas our tender process is designed to prefer those suppliers who have Living Wage Foundation accreditation or other accreditations that demonstrate a commitment to ethical practices.  

We are also rolling out an audit of our cleaning service provider; 30 cleaners are allocated by our cleaning supplier to service our six offices. The objective of our audit will be to ensure those cleaners have the right to work in the UK, have not paid or are indebted for a recruitment fee linked to their employment, have not had their passport retained, have a written contract of employment, are paid in line with at least the national minimum wage requirements, have access to a grievance procedure and have received relevant health and safety training. Reputable sub-contractors must be used when required.

The audit will include a review of documentation and interviews with those who attend to clean our offices.

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 regard the risk factors to be territorial and whether a supplier is a significant supplier of people. In the last year we concluded that our cleaning suppliers were a high risk supplier and that is why we are rolling out this audit. Our modern slavery procedures will continue to be risk based in this manner, with our attention focused on areas of higher risk.

Training

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, all staff are required to complete a video course that sets out the impact of modern slavery and the part we all play in its prevention.  

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. 

Responsibility

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 encouraged 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, this 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:

  • recruitment procedures to ensure that we do not engage in or procure slavery, servitude, forced labour or human trafficking; 
  • training for all staff to ensure they are aware of these obligations; 
  • staff induction where employees are made aware that they may and should report any modern slavery concerns to the risk and compliance team;
  • protection for employees making such reports in the form of a whistleblowing policy which makes direct reference to the Act;
  • procurement procedures that require relevant suppliers to comply with the Act;
  • checks on relevant suppliers at appropriate intervals aimed at detecting slavery, servitude, forced labour or human trafficking in our supply chain. Such checks are to be conducted by those overseeing procurement who will work alongside the risk and compliance team. Where concerns arise, the risk and compliance team will be informed and will decide on appropriate action, including external reporting if necessary.

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 needed. 

Board approval

This statement has been approved by the firm’s management, 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