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Modern slavery statement

Modern slavery statement

Modern Slavery Act – statement by Trowers & Hamlins LLP (the LLP)

This statement is made on behalf of Trowers and Hamlins LLP pursuant to s.54 of the Modern Slavery Act 2015 (the Act). The Executive 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 2017.

About the LLP
Trowers & Hamlins is an international law firm headquartered in the UK, with offices in Manchester, Birmingham, London, Exeter, Abu Dhabi, Dubai, Bahrain, Oman and Kuala Lumpur.

As a firm, we continue to look at ways in which we can all work together to create an environment where equality, diversity and inclusion are central to how we operate.

This statement forms part of our commitment and our responsibility to ensure that there is no modern slavery or human trafficking in our supply chain or in any part of our business.

Identifying and addressing risks within our supply chain
The LLP's suppliers include a wide range of industries including hospitality, cleaning services, maintenance, courier services, merchandise, conference suppliers and recruitment agencies.

Our initial risk assessment perceived the risk to the LLP to be low and to date we have not identified any serious modern slavery or human trafficking risks in our business or in our supply chain.

During the course of the past financial year key stakeholders within the business continue to conduct an assessment on all of our suppliers globally. During this assessment each supplier was allocated a risk category based on the potential risk such supplier may pose. This assessment was based on risk factors such as geographical risk, employment practices and sector risk.

Where we have identified suppliers which are at a higher risk for unfair working practices, modern slavery or human trafficking, we have completed a more in-depth assessment and required those suppliers to complete a self-assessment questionnaire. This requires suppliers to provide us with details of the size of their workforce, their nationalities and the employment practices which they use (e.g. zero hour contracts). Suppliers are also required to provide us with details of their policies and procedures, including details on their program to ensure that human trafficking and slavery does not exist within their operations and supply chain, audits of operations and suppliers, company standards on modern slavery and human trafficking for employees and contractors, and details on training to employees.

Training
Training continues to be an important part of promoting awareness and change. All staff globally have been provided with online compulsory training which provides information on the definition of modern slavery and human trafficking, practical examples of how slavery and/or human trafficking can take place within our business and our supply chains and how to report any concerns of modern slavery and/or human trafficking. Staff are also periodically reminded about the firms Modern Slavery policy.

Our Policies
In addition to our Modern Slavery Policy, we also have a number of other policies which together address our commitment to eliminating the risk of modern slavery and human trafficking taking place within our business and in our supply chain. This includes our policies on:

  • Anti-bribery and Corruption
  • Anti-money Laundering and Sanctions Compliance
  • Corporate Social Responsibility
  • Employee Code of Conduct
  • Whistleblowing

Action plan
During the course of the next year we shall –

Continue to assess the risk of modern slavery and human trafficking within our supply chain, and continue to require any suppliers which are identified at risk to complete a self-assessment. We will continue this assessment with a particular emphasis on communicating our required standards and behaviors which we expect form our suppliers to our international offices in relation to tackling modern slavery and human trafficking.

Begin introducing Key Performance Indicators such as:

  • Ensuring that all new suppliers complete a self-assessment in relation to modern slavery and human trafficking.
  • Introducing contractual requirements for all new suppliers and for the renewal of contracts with existing suppliers to ensure that all suppliers are contractually required to comply with our expected standards and behaviors in relation to Modern Slavery. 
  • Continue to assess as to whether our modern slavery policies and procedures are adequately addressing the modern slavery risks we face, by continuing periodic reviews. This also includes ensuring that our other policies which address issues related to Modern Slavery listed above; continue to do so, and to incorporate that into the periodic review of those policies.

Signed on behalf of the members of Trowers & Hamlins LLP
Sara Bailey (Designated Member)