Slavery & Human Trafficking
Statement on Slavery & Human Trafficking 2022
Section 54(1) of the Modern Slavery Act 2015 (the ‘Act’) requires any commercial organisation in any sector, which supplies goods or services, and carries on a business or part of a business in the United Kingdom, and is above a specified total turnover, to produce an annual slavery and human trafficking statement to be approved by their board and published on their website.
Clarke Willmott LLP (‘Clarke Willmott’) is committed to the prevention of the use of forced labour and has a zero-tolerance policy against human trafficking and slavery. This statement relates to the actions and activities of Clarke Willmott during the financial year ending April 2022.
Clarke Willmott is a national law firm with seven offices across England and Wales (registered number OC 344818), which provides a broad spectrum of legal services for businesses and individuals. We employ over 600 lawyers and support staff.
We pride ourselves on providing the best service for our clients. To do so we act with integrity and fairness. Clarke Willmott and its staff are committed to eradicating the threat of human trafficking and slavery where possible and we would expect no less of our clients or the suppliers we use.
Clarke Willmott will not use or allow the use of forced, compulsory labour, slavery, servitude, or human trafficking in the course of its business. This includes sexual exploitation, securing services by force, threats or deception and securing services from children and vulnerable persons.
Our employment procedures guarantee that Clarke Willmott conducts appropriate checks on all staff to ensure they can legally work in the United Kingdom. In addition, all internal policies are reviewed at least annually to ensure continued compliance with the Act. The following policies are relevant to the prevention of slavery and human trafficking in its operations:
Procurement & Outsourcing Policies. These establish that Clarke Willmott will continue to comply with the Act in respect of our relationship with all our suppliers. To operate successfully, we may acquire goods or services from third-party sources. Our supplier agreements include modern slavery clauses which the supplier must agree to before work is carried out.
Corporate Responsibility Policy. This policy is designed to ensure that Clarke Willmott is conducting its business responsibly. We devote considerable resources to various initiatives which have a positive impact on the community which we live and the wider environment.
Whistleblowing Policy. Clarke Willmott encourages all its employees to report any concerns related to the activities of the firm. The organisation’s whistleblowing procedure is designed to ensure that any matter raised under this procedure will be investigated thoroughly, promptly and confidentially, and the outcome of the investigation reported back to the individual who raised the issue. Additionally, the policy guarantees that no one will be victimised for raising a matter under this procedure.
Recruitment Policy. This confirms that Clarke Willmott will conduct checks on all staff to safeguard that they can legally work in the United Kingdom.
Employment Contracts. These include a clause confirming that the employee will comply with Clarke Willmott’s Modern Slavery Policy and any related procedures.
The advice of the National Crime Agency’s ‘Indicators of Modern Slavery’ is that some practice areas risk being exposed to human trafficking and slavery crimes. All staff at Clarke Willmott receive training on Clarke Willmott’s policies and any reported concerns will be dealt with in a swift and effective manner.
Supplier Adherence to the Firm’s Values
We have continued our efforts from 2021 to ensure all our suppliers incorporate and maintain their compliance with our policies on human trafficking and slavery.
Part of our procurement process requires any new supplier complete our questionnaire to ensure we are satisfied their commitment to preventing human trafficking and slavery mirrors that of Clarke Willmott. This process will ensure suppliers:
- Comply with the requirements of the Act (or equivalent).
- Provide Clarke Willmott with a copy of the supplier’s policy.
- Provide Clarke Willmott with a copy of the supplier’s Anti-Slavery Statement and confirmation of how and where this has been published.
- Provide confirmation as to whether the supplier has ever been prosecuted for an offence pursuant to the Act (or equivalent).
Prior to the formation of any contract with our suppliers, we add our own modern slavery clauses which ensure:
- Neither the supplier nor any of its officers, employees, agents or subcontractors have:
- Committed an offence under the Act;
- Been notified it is subject to investigations relating to an alleged breach under the Act; or
- Is aware of any circumstances within its supply chain which could give rise to an investigation or prosecution under the Act.
- The supplier complies with the Act and our modern slavery policy.
- Clarke Willmott will be immediately notified should the supplier have reason to believe failure of any of its requirements.
- Breach of supplier compliance will entitle Clarke Willmott to terminate the contract.
Through this, we are satisfied that our current suppliers make sufficient effort to ensure they do not have any involvement with human trafficking and slavery. Our suppliers also assure Clarke Willmott they continue to screen their own suppliers to ensure compliance with the Act.
If any responses are deemed unsatisfactory, our continued relationship with them will be determined by our Audit and Risk Committee. Similar assessments are carried out when considering the slavery and human trafficking risks of each new service supplier.
Our firm-wide procurement process has been maintained to reflect Clarke Willmott’s commitment to preventing human trafficking and slavery. Our procurement process ensures that, despite the size and complexity of the firm’s supplier needs, sufficient due diligence is carried out on all the firm’s prospective suppliers, no matter the size or relationship.
It is possible that allegations of human trafficking and slavery may be made, most likely, by whistle-blowers. If allegations do emerge, Clarke Willmott will comprehensively investigate any allegations that an outsourced service supplier is partaking in slavery or human trafficking. This investigation would be supervised by our Audit and Risk Committee.
The firm’s Risk Management and Compliance Team continue to monitor and improve, where necessary, all Clarke Willmott’s policies which are relevant to the prevention of slavery and human trafficking.
All management and staff undergo training regarding the firm’s policies to ensure that all employees understand our shared values and comply with our statutory obligations including those set out in the Act. We maintain a live database of all policies, which staff can readily access on the firm’s intranet. The firm’s Knowledge Services & Risk Management and Compliance teams are tasked with ensuring the firm’s policies are maintained and updated on a regular basis and all members are responsible for ensuring that all members of staff adhere to the firm’s values, standards and obligations.
Going forward, we will circulate, annually, a copy of this Statement to all employees along with additional information on our Modern Slavery and Human Trafficking Policy and procedures.
Clarke Willmott’s Wider Commitment to Preventing Modern Slavery
Clarke Willmott has previously supported Unseen, a charity which raises awareness of modern slavery and human trafficking. The firm is proud of its relationship with Unseen and learned from the valuable work that they do.
The firm pledged to work with Llamau (the chosen charity for the Cardiff office) in 2021. Llamau supports young people and women experiencing homelessness. Quite often, as a result of slavery & human trafficking, young people and women can find themselves alone, without a support system, in an unfamiliar country. Due to the covid-19 pandemic, Clarke Willmott has extended the support for this charity until 2023.
Key Performance Indicators
The key performance indicators (KPIs) will be that the responses from all current and future suppliers are satisfactory and continue to be satisfactory with regards to their efforts made to avoid human trafficking and slavery and adhere to the Act. Training records will be kept ensuring all existing and new staff members are up to date, and the central register will be reviewed quarterly. We are confident that through our process staff understand the signs attributed with modern slavery as well as the process and their key contacts in the event they wish to raise any concern.
This statement will be reviewed annually. The next review is due April 2023.