Human trafficking & slavery
Statement on Human Trafficking & Slavery 2018
The Modern Slavery Act 2015 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 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 LLP (‘Clarke Willmott’) during the financial year ending April 2018.
Clarke Willmott LLP is a national law firm with seven offices across the United Kingdom, which provides a broad spectrum of legal services for businesses and individuals. We employ over 600 lawyers and support staff.
Clarke Willmott LLP 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 Modern Slavery Act 2015. The following policies are relevant to the prevention of slavery and human trafficking in its operations:
- Outsourcing Policy. This establishes that Clarke Willmott LLP will continue to comply with the Modern Slavery Act 2015 and conduct annual reviews of outsourced suppliers.
- Recruitment Policy. This confirms that Clarke Willmott LLP will conduct checks on all staff to safeguard that they can legally work in the United Kingdom.
- Corporate Responsibility Policy. This policy is designed to ensure that Clarke Willmott LLP is conducting its business responsibly.
- Whistleblowing Policy. Clarke Willmott LLP encourages all of 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.
Supplier adherence to the firm’s values
Whilst Clarke Willmott LLP outsources few services, each outsourced service supplier’s conduct is carefully considered when awarding or renewing business. Efforts are made to certify that outsourced service suppliers are as committed to the prevention of human trafficking and slavery as Clarke Willmott LLP. Clarke Willmott LLP will not tolerate outsourced service suppliers who partake in any form of slavery or human trafficking as defined by the Act.
The outsourced service suppliers that Clarke Willmott LLP use have been contacted to confirm their positions with regards to human trafficking and slavery. They have been asked to provide a statement explaining the efforts made by them to avoid human trafficking and slavery within their organisations.
We have continued our efforts from 2017 to ensure all our outsourced suppliers incorporate and maintain their compliance with our policies on Human Trafficking and Slavery.
We are satisfied that sufficient efforts are made by our outsourced service suppliers to ensure that they do not have any involvement whatsoever with human trafficking and slavery. They have also provided Clarke Willmott LLP with assurances that they continue to fully screen their own suppliers to ensure that they are also compliant with the Act.
We are undergoing our annual review of outsourced service providers, incorporating changes from EU GDPR. 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 modern slavery and human trafficking risks of each new service supplier.
It is possible that allegations of human trafficking and slavery may be made, most likely by whistle-blowers. If allegations do emerge, Clarke Willmott LLP will comprehensively investigate any allegations that an outsourced service supplier is partaking in slavery or human trafficking. This investigation would be conducted by our Audit and Risk Committee.
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 Modern Slavery Act 2015. We maintain a live database of all policies, which staff can readily access on the firm’s intranet. The firm’s Risk and Compliance Team 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.
As part of our obligations under the Money Laundering Regulations 2017 we also carried out a firm-wide risk review. As a result of this review we identified the need to establish a centralised register of suppliers, intermediaries and associated persons. This has allowed the Risk and Compliance team a greater degree of oversight and review for ongoing and future arrangements in our supply chain in order to combat modern slavery.
Key Performance Indicators
The key performance indicators (KPIs) will be that the responses from our outsourced service suppliers are satisfactory and continue to be satisfactory with regards to their efforts made to avoid human trafficking and slavery. Training records will be kept to ensure all existing and new staff are up to date, and the central register will be reviewed quarterly.
This statement will be reviewed annually. The next review is due April 2019.