Modern slavery statement
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 (the Act) and sets out the steps Trowers & Hamlins LLP (the LLP) has taken to ensure that slavery and human trafficking is not taking place in our supply chain or in any other part of our business.
The LLP is committed to combatting modern slavery in all its forms. This is underpinned by our commitment to governance and accountability, as outlined in our responsible business report (An Agenda for Change) which forms a key part of the LLP's wider strategic objectives. This statement highlights the key activities we have undertaken in pursuit of this objective during this financial year.
The Management Committee of the LLP approved this statement for and on behalf of the members of the LLP. This statement relates to the period to 30 April 2023.
About the LLP
Trowers & Hamlins LLP is an international law firm headquartered in the UK, with offices in Manchester, Birmingham, London, Exeter, Abu Dhabi, Dubai, Bahrain, Oman and Malaysia.
We work to the highest professional standards and comply with all laws, regulations and rules relevant to our business and we expect the same from our suppliers and business partners. The LLP's supply chain includes the following industries:
- IT and telecommunications
- Facilities and office services (including cleaning, catering, security, facilities management and transport)
- Information services and knowledge management
- Media, marketing, promotions and events
- Employment, recruitment and employee benefits
- Finance and banking services
We have intrinsic core values around equality, diversity and inclusion and responsible business. The firm has a variety of policies to foster a positive and fair working culture including our Responsible Business Agenda and policies on: equality, diversity and inclusion; equal opportunities; and wellbeing and stress management.
We have a Whistleblowing Policy, a Bullying and Harassment Policy, alongside our culture of a non-discriminatory and open working environment which enables employees to report if they have concerns about any wrongdoing or breaches of the law or regulations. All concerns can be raised in confidence and without fear of disciplinary action.
We continually review our recruitment procedures and providers to ensure that all our employees are legally entitled to work in the jurisdiction which they are employed in.
We aim to ensure the wellbeing of all our employees by promoting mental and physical health through a variety of firm initiatives.
All employees in the UK are paid at least the minimum wage and in London employees and contractors whom we pay directly are paid the London Living Wage or above. For those suppliers where we are not in control of their wage structures, we ask them to provide confirmation that they are paying the London Living Wage (for services provided in London) or the minimum wage to those providing services outside of London.
Regarding the prevention of modern slavery in our supply chain, over the course of the previous year we have undertaken the following activities:
- Ensured that appropriate compliance procedures are in place for onboarding new suppliers. This enables us to identify and assess potential risk areas in our supply chains.
- Continued to communicate the process for onboarding new suppliers to stakeholders. We are currently undertaking an exercise to map this process and issue formal communications.
- Updated our due diligence and risk assessment processes for onboarding suppliers across our UK offices. We require new suppliers to complete our Anti-Bribery & Modern Slavery questionnaire. Further due diligence is undertaken on a risk-based basis depending on the responses to the questionnaire.
- Included a compliance section in our standard template ITT document, expressly referencing modern slavery, to ensure that this is appropriately considered at the outset of any potential supplier engagement.
- Updated the questions in our supplier questionnaire to ensure that information about wages and conditions are captured.
- Continued to communicate the standards and behaviours we expect from our suppliers to them, and continued our current procedures for ongoing monitoring of suppliers.
- Continuing to require our new and existing suppliers (upon renewal or evaluation of higher risk) where appropriate, to enter into contractual commitments to ensure compliance with the relevant rules and regulations, report instances of non-compliance and, where possible, a contractual right for us to exit triggered by any non-compliance.
- Continued to implement our training programme for all new joiners and employees to raise awareness about modern slavery and the various forms it can take and what action to take if modern slavery or human trafficking is suspected in a supply chain.
- Continued to communicate our Whistleblowing Policy and the systems we have in place to protect whistle blowers.
Signed by Paul Marco, Designated Member for and on behalf of Trowers & Hamlins LLP