Modern Slavery Statement for our financial year ending 30 April 2020
The United Kingdom Modern Slavery Act 2015 (“MSA”) requires certain businesses to provide disclosure concerning their efforts to ensure there is no modern slavery or trafficking in their organisation or supply chain.
The following is the statutory statement by Charles Russell Speechlys LLP made pursuant to section 54 of the MSA and constitutes our slavery and human trafficking statement for the financial year ending 30 April 2020.
This statement is published on behalf of Charles Russell Speechlys LLP. In this statement, references to “we”, “us”, “our” or the “firm” are references to Charles Russell Speechlys LLP and each of its subsidiaries.
This statement has been approved by the Executive Committee of the firm.
We take our duties of Corporate Social Responsibility seriously.
We take seriously our legal and compliance obligations in our business conduct and strive to observe these fully in our recruitment policies, vendor selection and supply chain management. These include our duties under the MSA.
We will not work with suppliers where it comes to our attention that they have been involved in offences related to, for instance, forced labour or child labour.
We are an international law firm that provides advice to a range of UK and international clients across a number of different specialisms.
We employ nearly 1,000 staff and have offices in London, Guildford and Cheltenham in the UK, and, outside the UK, in Hong Kong, Paris, Luxembourg, Geneva, Zurich, Qatar, Dubai and Bahrain.
Our supply chain
Our supply chain comprises the types of vendor expected for a professional services firm of our size and scale.
Our suppliers primarily relate to professional services, our premises and related facilities management, utilities, the providers of IT equipment and related services and catering services
Details of checks and due diligence conducted on members of the supply chain
In response to the MSA, we put in place the practice of auditing new and on-going members of our supply chain by requiring them to answer detailed questionnaires relating to their own businesses.
As part of this process, we required suppliers to divulge to us information about certain practices in order to assess whether there could be slavery or human trafficking in their organisation or supply chain. We are willing to terminate relationships with suppliers where they are found to present an unacceptable risk in terms of their modern slavery or human trafficking exposure. Fortunately, no such situation has arisen to date.
During the course of this year, we have enhanced our due diligence. First, we have conducted a desktop analysis on suppliers to ensure that where applicable, they have satisfied their legal obligations to publish statutory disclosures pursuant to section 54 of the MSA. We have also engaged a third party to conduct checks on our suppliers and flag any issues such as slavery related prosecutions or convictions or failures to publish section 54 disclosure statements.
We now also have in place a policy for asking suppliers about their anti-slavery policies and practices through part of an on-boarding process when they register through the firm’s procurement portal.
Our facilities team is currently also putting in place a Code of Conduct for suppliers to make clear to them the principles of our firm and the standards we expect from them.
We periodically make training on slavery and human trafficking available to staff. This in particular applies to our HR and procurement (facilities) staff who are at the greatest risk of encountering modern slavery or human trafficking in their day-to-day functions.
Previously, our training has been provided face-to-face although this has been made more difficult during the COVID-19 pandemic. We have made updated training materials available to staff via the Internet.
The level of training needed is proportionate to the role of the member of staff concerned and the likelihood of their becoming exposed to instances of modern slavery or human trafficking in carrying out their everyday duties. There will be a particular focus on our HR and procurement management staff.
We are committed to the principle that those who work for us must have chosen their work freely and must be treated with dignity. We pay our UK staff the living wage. We also ensure that interns are paid fairly. An area of our due diligence is dedicated to the practices of agencies who refer staff to us and we are keen to ensure that intermediaries do not deal with workers in a way which is inconsistent with our standards.
Violations by suppliers
We take very seriously any instance of suppliers being involved directly or indirectly in modern slavery or human trafficking. Our response to any such discovery will depend upon a number of factors, including the number of victims involved, the gravity of the human rights violations concerned, whether the supplier was involved directly or indirectly and whether or not the supplier has previously been involved in such conduct.
Violations by employees
We will not tolerate any of our officers or employees being involved in modern slavery or human trafficking. Any such employee can expect to find themselves the subject of serious disciplinary actions in accordance with our employment manual and contract of employment.
It is also the intention of Charles Russell Speechlys LLP to set up a reporting procedure through which our employees can raise any suspicions they may have from time to time that modern slavery or human trafficking may be taking place in our organisation or supply chain. Employees will be reassured that where suspicions are reported in good faith, they will receive no sanction if these ultimately turn out to be unfounded.
Charles Russell Speechlys LLP has considered in detail the nature of its operations and supply chain. This process has guided how we channel our resources in terms of training and supplier auditing.
One area of risk we have identified is employment agencies who provide us with staff referrals. We have, however, conducted due diligence of agencies and were satisfied with the responses received.
We have previously provided support to the charity Anti-Slavery International. This has entailed attending meetings with Anti-Slavery International to brainstorm and provide ideas for how businesses can more effectively combat slavery. One of our partners, Paul Henty, ran the 2019 London Marathon and raised funds for Anti-Slavery International.
We advise several clients in different sectors and assist them in the adoption of best practice and legal compliance.
Effectiveness of policies
In general, we keep our slavery and human trafficking policies and due diligence processes under review to ensure their effectiveness in achieving the desired results.
We apply the following KPIs as metrics to determine whether our policies and procedures are producing the desired effect:
(a) audits having been completed on a significant proportion of suppliers within the relevant financial year. This is an area we need to improve on during the current financial year;
(b) the audit process not having given grounds for any concerns regarding modern slavery or human trafficking and Charles Russell Speechlys LLP not having otherwise received reports of suppliers being complicit in such practices;
(c) the completion of training for all key procurement and supply management personnel; and
(d) the implementation of an operational whistleblowing facility for staff to enable them to report on a confidential basis suspicions of modern slavery or human trafficking occurring in our business or supply chain.
Any questions or queries in relation to this statement should be directed to Paul Henty email@example.com
SIGNED by SIMON RIDPATH for and on behalf of CHARLES RUSSELL SPEECHLYS LLP