�������ϲ�����

For the financial year ending 30 April 2021

Introduction

This statement has been published in accordance with the requirements of section 54(1) Modern Slavery Act 2015 (the Act). It sets out the steps taken by �������ϲ����� LLP during the financial year ended 30 April 2021 to ensure modern slavery and human trafficking, collectively referred to as “modern slavery” in this statement, is not taking place in any part of our business or any of our supply chains. �������ϲ����� has an unwavering approach to tackling modern slavery of any kind within our organisation and supply chains. We are committed to improving our practices to enable us to identify and eradicate any modern slavery within our firm and supply chains.

Our structure and business as at 30 April 2021

�������ϲ����� is a national law firm supplying legal services, advising clients across the private and public sectors. We are a limited liability partnership registered in England and Wales (registered number OC306448). We are owned by our 90 members. Our head office is based in Nottingham and we also have offices in London, Birmingham, Manchester and Exeter. We currently have 963 employees, which includes 116 partners. For the financial year ended 30 April 2021 we had an annual turnover of £80m.

As a result of the Covid-19 pandemic, the majority of our partners and employees continue to work from home. It is anticipated that as the social restrictions are lifted there will be a sizable proportion of employees who will continue to work remotely in the long term or adopt a hybrid of home and office working following the introduction of our ‘One Firm, wherever you are’ approach.

Our supply chains

We are continually reviewing how we engage the services of our suppliers and monitor them. As a provider of legal services our suppliers support the operation of our business and very broadly fall into the following general categories:

• consumables
• employee benefits
• food and beverage
• telecommunications and information technology
• facilities management (building services)
• business support services (switchboard, off site storage, document production etc.)

Our supply chains are mainly UK based. We identify our suppliers via both risk and value criteria. In terms of risk we identify whether they are low, medium, or a high-risk supplier and in terms of value we identify them by commodity, operational, tactical or strategic which subsequently identifies the due diligence and supplier management process to be adopted.

Our policies

As reported in our previous statements, our internal policies, including our Anti Modern Slavery Policy and Whistleblowing Policy, are reviewed annually to ensure our compliance with the Act and appropriate changes are made if there are lessons learnt during the previous year.

Due diligence processes

As part of our due diligence processes we now require a declaration from all new suppliers that they comply with applicable legislation in relation to modern slavery. We have finalised updates to our supplier questionnaire.

We have introduced specific measures to ensure that our obligations under the Act are passed through our supply chain, these include:

• a commercial review for non-commodity contracts to ensure that appropriate contractual provisions are incorporated into new supplier contracts and renewals of existing contracts, which require a supplier to take reasonable steps to ensure that modern slavery is not taking place in its business or in its supply chains (where applicable).
• continuing to provide advice to and work with our clients on how to eradicate the risk of modern slavery in their businesses and supply chains.

During the financial year covered by this statement, our supply chain processes were followed with over 30 suppliers despite challenges brought about by Covid-19.

In 2020-21 we planned to recruit a Procurement Manager to oversee our complete procurement processes. This was put on hold due to the pandemic but will be a priority for 2021-22. At the present time a Project Lead and former senior equity partner of the firm continue to take responsibility for this.

Risk assessment

As part of our ongoing firm wide risk assessment, we continue to monitor our procurement process via the application of our procurement policy. The due diligence process identifies if the supplier is low, medium or high risk – which is assessed via a number of factors. In addition, as part of the due diligence process ‘red flags’ are raised where responses and information do not comply with our internal policies, i.e. Modern Slavery statements. In addition, we use a risk matrix to assess our risks and maintain a risk register which prioritises business risks.

Our Risk and Compliance Committee have considered the risks around modern slavery.

Measuring effectiveness

We believe that by developing the due diligence process outlined above we will have an effective means of identifying whether modern slavery is taking place in any parts of our business or any of our supply chains. We have introduced a tracking system to ensure that procurements go through all necessary internal procedures for approval. Once in post, our Procurement Manager will further develop how we monitor the relationship with our suppliers.

�������ϲ����� is not aware of any incidents of modern slavery during the financial year. In the event of such an event occurring or an allegation being made, the matter will be initially reported to our Risk & Compliance team to determine appropriate action.

Training

Our Anti Modern Slavery Policy applies to all persons working for us or on our behalf in any capacity. Our Anti Modern Slavery Policy and Whistleblowing Policy are available on our intranet for all staff to access. Our Anti-Money Laundering training was reviewed during 2020-21 and a decision made to provide more focussed group training on modern slavery to those staff members more likely to be involved in procurement activity.

Training for those members of staff took place on 20 May 2021.

Board approval

We have agreed management responsibility for this statement and our exec has approved and fully supports these initiatives.

Signed by:

Richard Medd, Managing Partner, Designated Member �������ϲ����� LLP

Date: 6 July 2021