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For the financial year ending 30 April 2024

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 2024 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 2024

�������ϲ����� is a UK and Ireland based law firm supplying legal services, advising clients across the private and public sectors.

�������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 98 members.

Our head office is based in Nottingham and we also have offices in Birmingham, Cardiff, Exeter, Manchester and London. We currently have 993 employees, which includes 111 partners.

For the financial year ended 30 April 2024 we had an annual turnover of £118m.  

Since our last statement our business has taken the decision to change our financial year end for 2024/25.  The new financial year will end on 31 March 2025.

Our supply chains

Our supply chains cover 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 catering, 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.

Most 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, Whistleblowing Policy and Supplier Due Diligence Policy.  

We conducted an annual review of these policies and they are accessible to all our people via our intranet.

Due diligence processes

We prioritised a risk-based approach to combating modern slavery, with due diligence undertaken for all but the lowest risk, low spend, one-off suppliers.

Requestors for new supplier engagements or contract renewals were required to ensure due diligence was completed prior to engagement or renewal, and new suppliers were not be set up for payment until this was complete.

For all in-scope suppliers, we performed an initial risk assessment consisting of 12 questions, including three relating to modern slavery.

All suppliers were required to provide a link to their modern slavery statement (if applicable).

Enhanced risk suppliers were additionally required to provide an overview of their approach to assessing and monitoring the risk of modern slavery within their business and supply chains.

Suppliers with increased modern slavery risks received a specific modern slavery form to complete, which required additional information or actions to be taken to check for modern slavery, details of any examples of modern slavery identified within the business or its supply chains in the past two years, and a copy of their anti-modern slavery policy. In the year covered by this statement, eight suppliers triggered this additional level of due diligence.

Our Risk and Compliance team reviewed responses to due diligence questions, with any risks communicated to the relevant director, head of department, or partner via a due diligence summary. Risks were graded red, amber, or green, with red-rated risks escalated to our Risk and Compliance Committee. We remained committed to ensuring that our operations were conducted ethically and responsibly, and continued to monitor and assess the risk of modern slavery in our business and supply chains to take appropriate actions to address any risks that arose.

Since our last slavery and human trafficking statement we introduced a new Supplier Code of Conduct which requires suppliers to comply with the Act. This includes not supporting or engaging in any form of modern slavery or human trafficking. Suppliers were also expected to report any incidents of modern slavery found in their business or supply chains.

The purpose of these requirements was to ensure that suppliers operate ethically and treat workers with respect and dignity, and to prevent any form of exploitation or abuse of workers. Suppliers were required to also have processes in place to maintain the standards and comply with our Supplier Code of Conduct at all times and report any actual or suspected breaches to us. While we reserved the right to terminate involvement with suppliers where the breach is sufficiently serious or remains unremedied within a reasonable period, where possible, our preference remained to work with suppliers, to resolve any suspected labour violations.

Risk Assessment

Our Risk and Compliance team provides an annual report to our Risk and Compliance Committee and Executive Committee, which includes our assessment of the risk of modern slavery within our business and its supply chains. The report outlines the actions we have taken and recommendations for the forthcoming financial year to improve transparency and awareness. While we have assessed the overall risk of modern slavery across our business and supply chains to be low, we remained committed to implementing proportionate measures to identify and minimise the risk of it occurring.

We undertook at least baseline modern slavery due diligence on all our suppliers.  

Within our supply chains we identified that the building services category is most at risk of modern slavery. Therefore, we worked closely with those suppliers to understand the steps they take to assess and manage the risk of modern slavery in their businesses and their supply chains.

Since our previous slavery and human trafficking statement, we re-introduced our catering services at our Nottingham head office.

Given the increased risk associated with these types of services, we performed enhanced supplier due diligence and were closely involved in the recruitment of catering staff. To further mitigate the risk of modern slavery, we included comprehensive anti-modern slavery provisions in our contract with the supplier. We also set clear expectations that the training provided to the supplier's staff at all levels ensured ongoing awareness of modern slavery.

We took a proactive approach to mitigate modern slavery and actively engaged with our clients' supplier due diligence processes. 

As a supplier of services to public sector organisations, we were asked to engage with the Modern Slavery Assessment Tool (MSAT) for a specific contract. We are currently in the process of completing this assessment, which will further help us identify and address any potential risks of modern slavery in our business and supply chains. 

Measuring Effectiveness

Our tracking and supplier due diligence processes ensure that all supplier engagements went through the appropriate due diligence and approval procedures.  Since the launch of our due diligence process and platform, we have identified eight suppliers that triggered our enhanced due diligence requirement. Of these, four were due to the offshore location or nature of the services, and four were due to the use of unskilled labour or where there was a higher risk associated with the nature of the services, such as catering. Following a thorough review, we were satisfied that no further action was necessary.

Training

While we had initially planned to roll out training to relevant staff, we instead focused on implementing proportionate measures to identify and minimise the risk of modern slavery taking place in our business or its supply chains. Our employees received information on the policies and procedures they must follow relating to their work, and we are committed to ensuring that they are equipped with the necessary knowledge and skills to identify and manage any risks that may arise. In line with our risk-based approach, we will continue to reflect on this to ensure that our employees are trained to address any risks of modern slavery. 

Board approval

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

Signed by:

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

Date: 25 July 2024