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 and publish an annual slavery and human trafficking statement.
This statement relates to the actions and activities during the financial year ending April 2018 and is reviewed annually. Clarke Willmott LLP is committed to the prevention of the use of forced labour and has a zero tolerance policy for human trafficking and slavery.
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 500 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 LLP conducts appropriate checks on all staff to ensure they can legally work in the United Kingdom.
In addition, all internal policies are reviewed regularly to ensure continued compliance with the Modern Slavery Act 2015.
Clarke Willmott LLP operates the following policies which 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.
In early 2017, all our outsourced suppliers were asked to incorporate a formal change to their contracts with us to confirm that they would comply with our policies on Human Trafficking and Slavery.
The responses from these suppliers have been positive, and 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 fully screen their own suppliers to ensure that they are also compliant with the Act.
Going forward, reviews with outsourced service suppliers regarding human trafficking and slavery will be conducted on an annual basis. If the responses are deemed unsatisfactory, our continued relationship with them will be determined by our Audit and Risk Committee. Similar assessments will be 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.
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.
This statement will be reviewed annually by our Risk & Compliance department. The next review is due April 2018.