Human trafficking & slavery
Statement on Human Trafficking & Slavery 2019
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 2019.
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:
- Procurement Policy. This establishes that Clarke Willmott will continue to comply with the Modern Slavery Act 2015 in respect of our relationship with all our suppliers.
- 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
We have continued our efforts from 2018 to ensure all our suppliers incorporate and maintain their compliance with our policies on human trafficking and slavery.
Efforts are made to certify that all our current and future suppliers are as committed to the prevention of human trafficking and slavery as Clarke Willmott LLP. Clarke Willmott LLP will not tolerate any suppliers who partake in any form of slavery or human trafficking as defined by the Act.
We are satisfied that sufficient efforts are made by our current 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.
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 updated and improved to reflect Clarke Willmott’s commitment to preventing human trafficking and slavery. The updated 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. Once a supplier has been approved, we also ensure appropriate clauses are incorporated into the supplier agreement to reflect the firm’s commitment to the prevention of slavery and human trafficking.
The Risk and Compliance Team has also assisted the Clarke Willmott’s Facilities Management Team, who work closely with many of the firm’s suppliers, with drafting supplier agreements for use with all future suppliers, which include clauses stating the firm’s commitment to preventing slavery and human trafficking.
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 supervised by our Audit and Risk Committee.
The firm’s Risk 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 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 Knowledge Services & Risk 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.
Clarke Willmott’s Wider Commitment to Preventing Modern Slavery
The firm has recently completed a two-year period in which Unseen were the Bristol office charity.
Unseen provide victims of human trafficking and modern slavery with support, shelter, and ongoing care, as well as working with the Home Office and the UK’s Human Trafficking Centre to help develop and shape UK policy.
As well as helping to raise awareness among Clarke Willmott staff, the firm also made significant contributions to Unseen in its efforts to combat modern slavery.
Clarke Willmott and its staff are proud of their relationship with Unseen and learnt from the excellent work that they do.
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. Training records will be kept to ensure all existing and new staff members are up to date, and the central register will be reviewed quarterly.
This statement will be reviewed annually. The next review is due April 2020.