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For the financial year ending 30 April 2023

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 2023 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 and the effectiveness of such steps. 

Our structure and business as of 30 April 2023

�������ϲ����� is a UK and Ireland based law firm supplying legal services, advising clients across the private and public sectors. Since our last statement, we have opened an office in Dublin and formed �������ϲ����� Ireland LLP. �������ϲ����� is the brand name under which �������ϲ����� LLP and �������ϲ����� Ireland LLP provide legal and other services to clients.

�������ϲ����� Ireland LLP is a limited liability partnership registered in the Republic of Ireland, regulated by the Law Society of Ireland and authorised by the Legal Services Regulatory Authority to operate as a limited liability partnership. A list of its partners is available at its principal place of business at 2 Hume Street Dublin 2 D02 FT82.

�������ϲ����� LLP is a limited liability partnership registered in England and Wales (registered number OC306448). We are owned by our 94 members. Our head office is based in Nottingham and we also have offices in London, Birmingham, Manchester, Exeter and Cardiff. We currently have 916 employees, which includes 85 partners. For the financial year ended 30 April 2023 we had an annual turnover of £105m.

Our supply chains

Our supply chain covers the procurement of goods and services to support the operations of our business and services to our clients. These fall into the following categories:

• IT – hardware, software and infrastructure, including hosting;
• Employee benefits;
• Telecommunications;
• Building services including cleaning, security and other facilities management;
• Business support services including document production and storage; 
• Recruitment agencies;
• Professional services including barristers, medical professionals and various consultants and experts.

The majority of our suppliers and supply chains are UK based. 

Our policies 

Our relevant internal policies continue to consist of our Anti-Modern Slavery Policy, Procurement Policy and Whistleblowing Policy.  In addition, we have introduced a Supplier Due Diligence Policy which sets out our approach to supplier due diligence.  We conduct an annual review of these policies and they are accessible to all our people via our intranet.

Due diligence processes

In line with our risk-based approach, we are pleased to report that our new due diligence process and platform were launched in summer 2022, followed by a new supplier due diligence policy in autumn 2022.  The scope of the policy has been significantly widened and due diligence must now be performed for all but the lowest risk, low spend, one off suppliers.  Requestors for a new in-scope supplier engagement or contract renewal with an existing supplier are required to ensure that due diligence is completed prior to engagement of the supplier or renewal of the contract.  New suppliers will not be set up for payment until this is complete.

For all in-scope suppliers, we perform an initial risk assessment consisting of 11 questions, including three relating to modern slavery, covering the country of operation, the use of material amounts of unskilled labour and the type of service being provided by the supplier.  All suppliers where one or more risk is identified via the risk assessment will be classed as enhanced risk, with over 60% of our suppliers falling into this classification.  All enhanced risk suppliers are required to provide (i) a link to their modern slavery statement (if applicable); and (ii) an overview of their approach to assessing and monitoring the risk of modern slavery within their supply chain.

Any suppliers where the risk assessment highlights increased modern slavery risks will receive a specific modern slavery form to complete.  This requires the supplier to provide additional information including their actions taken to check for modern slavery, details of any examples of slavery etc. identified within the company and its supply chain in the past two years and a copy of their modern slavery policy.  As expected from the low risk profile of the firm, there are very few suppliers which trigger this additional due diligence, with only four suppliers identified since we launched the platform in summer 2022. 

Where appropriate, responses to the due diligence questions are reviewed by our Risk and Compliance team, with any risks being communicated to the relevant director, head of department or partner via a due diligence summary.  Each of the risks outlined in the due diligence summary is graded red, amber or green.  A red rated risk cannot be accepted by the relevant head of department etc. but must be escalated to our Risk and Compliance Committee.

We have also drafted a new Supplier Code of Conduct which reiterates the expectations we have of our suppliers to act in an ethical and compliant manner, including complying with modern slavery legislation and reporting to us any incidents of modern slavery or human trafficking discovered within their business or supply chain.  This is currently going through our internal approvals process and should be live shortly.

Risk Assessment 

The Risk and Compliance team report annually to our Risk and Compliance Committee and our Exec.  This report summarises our assessment of the risk of modern slavery within our business and supply chains and outlines the actions we have taken and the recommendations for the forthcoming financial year to continue improving transparency and awareness.

Whilst we have assessed the overall risk of modern slavery across our business and our supply chains to be very low, ensuring we put proportionate measures in place to identify if modern slavery is happening in our business or supply chains and to minimise the risk of it occurring remains a priority.

Although we undertake at least baseline modern slavery due diligence on all of our suppliers, the elements of our supply chains which are most at risk of modern slavery are within our building services category.  We work closely with those suppliers to understand the steps they take to assess and manage the risk of modern slavery.  

Whilst we continue to operate a hybrid working model across our offices, following the end of lockdown restrictions brought in in response to the COVID-19 pandemic we have seen an increase in the number of staff returning to our physical offices.  This has resulted in us considering the re-introduction of our catering offering in our Nottingham head office.  Given the increased risk of these types of services, we have performed enhanced due diligence on the proposed supplier.  We have been closely involved with the recruitment of the staff who will be working at our site and we are including comprehensive anti-modern slavery provisions in our contract with the supplier as well as clear expectations that the training given to the supplier’s staff at all levels ensures ongoing awareness of modern slavery.  

Measuring Effectiveness 

Our tracking and supplier due diligence processes ensure that all supplier engagements go through the appropriate due diligence and approval.  Since we launched our new due diligence process and platform, four suppliers have triggered our enhanced due diligence requirement where there were links to either the use of unskilled labour or off-shore entities.  No further action was deemed necessary.   

We were delighted to be invited to the House of Lords in January 2023 to attend the official launch of the new British Standard on modern slavery (BS 25700:2022).  This standard now provides a helpful framework against which to measure what we are doing to tackle modern slavery and to assist us to constantly improve in this area.

We are not aware of any incidents of modern slavery having occurred during the financial year across our business or within our supply chains.

Training 

During the last financial year we have engaged with the Gangmasters and Labour Abuse Authority and the University of Nottingham’s Rights Lab to deliver in-person modern slavery training in our Nottingham office.  The insightful sessions provided an excellent training opportunity both for our clients and for ourselves, as the unique perspectives of these organisations enabled us to engage with different aspects of the subject area.  The training was attended by our Risk and Compliance Director for this reason, to assist with expanding our thinking and knowledge both from an academic and practical perspective.  

Although we had planned to roll out training, when we assessed the available products on the market and the risks we experienced, we decided to adopt a different approach.  Our Risk & Compliance team will assess the requirements for training key individuals in the forthcoming year.

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: 29 June 2023