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This statement is made on behalf of Stephenson Harwood LLP and each of its affiliated entities. References to "us", "our", "we" or the "Firm" are references to each of these entities.
This statement sets out the steps that we have taken to mitigate the risk of modern slavery and human trafficking occurring within our operations or our supply chains. This statement is made pursuant to section 54 (1) of the UK Modern Slavery Act 2015 with respect to the financial year ending 30 April 2024.
Our structure
Stephenson Harwood LLP and its affiliated entities are separate members of the international legal practice known as Stephenson Harwood providing services to clients around the globe. We have 8 offices across the United Kingdom, Europe, Asia and the Middle East with over 1,300 people worldwide, including over 200 partners. Details of the Firm’s international offices can be found on the Firm's website.
Our operations
Our principal activity is the provision of commercial legal services to our clients. We operate across 8 offices located in the United Kingdom, Europe, the Middle East and Asia. Our activities are regulated in each of the jurisdictions in which we operate and as such our people are required to conduct themselves according to specific standards. This includes, but is not limited to, the requirements of the Solicitors’ Regulation Authority of England and Wales.
We consider the risk of modern slavery and human trafficking existing within our operations to be relatively low given that we are a regulated practice providing legal services to clients, and primarily employing legal professionals and qualified legal support staff. However as detailed below this risk assessment is under regular review.
Our supply chain
Our supply chain predominantly consists of goods and services procured to enable us to deliver legal services to our clients. The sourcing and purchasing of goods and services is supported across the Firm by our procurement team based in London. The key categories of goods and services that we procure are property space, facilities management, human resources, information technology, other professional services, cleaning, hospitality and catering.
Identifying risks of modern slavery in our supply chain
The legal and regulatory risk team, together with the procurement, the HR and the inclusion and diversity teams, undertakes an annual assessment of the risks of modern slavery in our business and supply chain, and actions are agreed and implemented to mitigate any identified risks.
To identify and assess any actual or potential involvement in modern slavery in our supply chain, we risk rate our suppliers, including according to factors that might indicate a high risk of modern slavery such as the location from which services are provided or goods are manufactured and the sectors or activities which present a high risk of modern slavery.
We have identified that the parts of our supply chain that carry a potential risk of modern slavery are predominantly those that involve the purchase of goods and services in industries where a large proportion of people are paid low wages.
Our assessment continues to be that the Firm and its supply chain pose a low risk with respect to modern slavery and human trafficking. To date, we are not aware of either having occurred within the Firm or within its supply chain.
Addressing our supply chain risk
Our modern slavery strategy and due diligence process is developed and reviewed by our Procurement and Risk and Compliance teams annually to ensure that we take a coordinated approach across the Firm.
The steps we are taking to assess and manage modern slavery and human trafficking risks are outlined in this statement. We will continue to update such assessments and steps on an annual basis to gain further visibility into our supply chain.
We seek to mitigate the risk of modern slavery in our supply chain by:
- investing in educating our procurement team to recognise the risks of slavery and human trafficking in our business and supply chain. We provide mandatory modern slavery e-learning for all relevant employees;
- requiring all our suppliers to complete our Supplier Accreditation Questionnaire. The Supplier Accreditation Questionnaire asks about their policies and procedures (including whether they have a Modern Slavery policy) and whether they have various accreditations (including the Living Wage Accreditation). We review the supplier's responses, apply risk ratings, and will follow up on any that cause concern ensuring that we do not renew or award contracts to any supplier that presents a medium or high risk of modern slavery;
- implementing a whistleblowing procedure that provides a confidential mechanism for individuals to disclose any suspicions of impropriety. It is the responsibility of those partners and employees within the Firm who have significant procurement-related responsibilities and supplier interaction to use all reasonable endeavours to detect, report and prevent modern slavery from occurring within our business or supply chain;
- the fact that the majority of our offices and suppliers are based in low-risk locations; and
- ensuring that contractual terms with our suppliers include standard warranties that the supplier will comply with (and ensure that its agents, subcontractors and employees comply with) all applicable laws (which shall include the Modern Slavery Act).
- In the event that we discover a potential incidence of modern slavery within our supply chain, we would seek to work with the supplier to investigate the concern and implement corrective and remedial action. Where appropriate, we would seek to terminate our agreement with them and notify the relevant authorities.
Our policies
We are committed to acting ethically and with integrity in all our business dealings and relationships and have a zero-tolerance approach to human trafficking and modern slavery. Our approach to the identification of modern slavery risks and the steps to be taken to reduce the risk of modern slavery and human trafficking in our operations and supply chain is supported by a number of internal policies and standards. These include:
- Anti-bribery and corruption policy – this policy prohibits bribery and related corrupt activities and includes safeguards ensuring that we detect and prevent bribery and corruption and meet our regulatory obligations and commitment to act professionally, fairly and with integrity in all our business dealings and relationships wherever we operate.
- Anti-money laundering and counter terrorist financing – this policy documents our approach to meet our anti-money laundering and counter terrorist financing obligations. This includes our client on-boarding process and the undertaking of client due diligence measures in accordance with applicable laws in the jurisdictions in which we operate.
- Equality, diversity and inclusion policy - we are committed to maintaining and developing a working environment that promotes inclusive and equitable practices, and to empowering our people and ensuring every individual is treated with dignity and respect. This extends to our relationships with clients, suppliers, contractors and third parties.
- Harassment and bullying policy - the Firm is committed to creating an inclusive work environment free of bullying and harassment where everyone is treated with dignity and respect.
- Modern slavery policy: this policy sets out the Firm's commitment to transparency in its business and the high standard it sets for itself and its contractors, suppliers and business partners with respect to the need both to identify and tackle modern slavery. This policy highlights that it is the responsibility of all partners and employees of the Firm with significant procurement-related responsibilities and supplier interaction to use all reasonable endeavours to detect modern slavery within our supply chain. In addition, it is the responsibility of all partners and employees of the Firm, regardless of their role, who have a suspicion or concern that modern slavery may be occurring anywhere within our business or supply chain to report any such suspicion or concern.
- Our recruitment process and pre-employment screening – this process ensures that our personnel have the appropriate rights to work and are engaged by the Firm in accordance with local employment legislation.
- Procurement policy: this policy ensures consistency and oversight of the procurement of goods and services across the Firm, and ensures suitable vetting and the on-going management and review of our supply chain.
- Whistleblowing policy: the purpose of this policy is to encourage and empower people across our offices to raise any concerns to us as soon as possible, including in relation to modern slavery issues, and to feel safe in doing so. Our approach is supported by a 24/7 confidential reporting service, SafeCall, which is managed by an independent third party.
Our people
We are committed to complying with all applicable laws relating to the recruitment, employment and remuneration of all our employees. We are committed to ensuring compliance with all relevant employment legislation and that remuneration is open, transparent, fair, equitable, and competitive in the market in which we operate.
We are an accredited Living Wage employer which means we are committed to paying a wage rate in the UK based on the cost of living. Where our overseas offices are in a jurisdiction with a statutory minimum wage, we pay above that minimum wage. In Dubai, where there is no such minimum wage, we benchmark every job role against the market to make sure that everyone is paid fairly.
We continue to provide pro bono services to groups of individuals that are vulnerable to being exploited with respect to their working conditions and remuneration, including domestic workers in Hong Kong and victims of wage theft in the UK.
Our training
All partners and employees upon joining the Firm are required to attend a live risk management induction training session, which includes information concerning the Modern Slavery Act and how the legislation, and the principles underpinning it, are captured and complied with in the context of the Firm's procurement processes.
In addition mandatory detailed modern slavery training is undertaken by members of our central management team, the head of each business services department and those employees with significant procurement-related responsibilities and supplier interaction. This ensures that those individuals who are most exposed to modern slavery risks, and those best situated to take action to mitigate these risks, will benefit from an in-depth understanding of modern slavery and how to combat it.
Performance indicators
We monitor the number of people who have completed our internal modern slavery training sessions and retain attendance logs.
To date no instances of modern slavery or human trafficking have been recorded within our operations or our supply chain.
Looking forward
In the financial year ending 30 April 2025, we will continue to develop our processes to address modern slavery risks occurring in our operations and supply chain. It is intended that these steps could include:
- Review, and where applicable update, all applicable polices to ensure continued compliance with the Modern Slavery Act 2015;
- continue to assess and monitor the risks in our operations and supply chain using the systems and tools outlined above;
- continue to risk assess our existing supply chain and continue to evaluate new suppliers using the Supplier Assessment Questionnaire and ensure that responses for all current and future suppliers are satisfactory with regard to their efforts made to prevent human trafficking and modern slavery; and
- continue to provide internal training on modern slavery awareness and prevention to new joiners and other relevant individuals within the Firm.
Designated Member - Paul Thwaite
For and on behalf of Stephenson Harwood LLP
Date: 5 September 2024