Modern Slavery – Slavery and Human Trafficking Statement
Slaughter and May is a leading international law firm, providing a full and extensive range of legal services to a diverse range of clients.
We seek excellence in every aspect of our business and are committed to the highest standards of professionalism, ethics and integrity. We are committed to conducting our business in a lawful manner and this includes engaging with our suppliers to support them in working against modern slavery.
As required by the Modern Slavery Act 2015 (the “Act”), this statement describes the steps which Slaughter and May has taken during the financial year ended 30 April 2020 and beyond to ensure that slavery and human trafficking is not taking place in any of our supply chains, or in any part of our own business. Slaughter and May Services Company, the in-house company that we use to engage our staff, has a separate statement.
In London we practise through a general partnership which also has offices in Brussels and Beijing. In Hong Kong we practise through a separate partnership. For further information about our business model, including how we are regulated, see the Legal and Regulatory Information on our website.
Supply chain relationships
Our key suppliers are the businesses which help us to run our premises, such as our catering, cleaning and security providers, or who supply us with the technology we need to deliver our legal services to our clients. We tend to foster long-term relationships with these first-tier suppliers with regular renewals of contracts to ensure we actively reassess their services and to help us work with suppliers to strengthen their approach. We also avoid making demands of our suppliers that might lead to them violating human rights. For example, we require our catering, cleaning and security suppliers to pay their personnel, who work at our premises, a salary which is equivalent (at least) to the London Living Wage.
Supplier Code of Business Conduct
We expect our suppliers to have fair employment practices, as articulated in our Supplier Code of Business Conduct. This encourages our suppliers to conduct their businesses ethically and we ask key suppliers to sign it to make their commitment to fair employment practices clear. A supplier’s compliance with our Supplier Code of Business Conduct is an important factor in us deciding whether to form, continue or renew a relationship with them. Any breach of our Code by a supplier, including not having fair employment practices which prohibit modern slavery, may result in us terminating our arrangements with the supplier. Our standard supplier contracts also include specific obligations on modern slavery.
As well as our own offices, we have close working relationships with other leading law firms across the world. However, we have no exclusive alliance with other law firms and are therefore independent and able to work alongside the lawyers selected by our clients in any jurisdiction. Ordinarily our clients engage their lawyers direct but, occasionally, we may do so on their behalf. If this is done on a sub-contracted basis, we generally rely on our knowledge of the other law firm and their business and the fact that they are regulated and/or committed to high ethical standards and would not usually send them a copy of our Supplier Code of Business Conduct.
In March 2017 we held a “Supplier Symposium” at our offices, with a programme which included training for our key suppliers on the requirements of the Act as well as our own ethical expectations in this area. Following the success of this event a further symposium was held in February 2018.
We have a face-to-face training programme for our senior management team as well as those of our employees who have responsibilities in relation to engaging the firm’s suppliers. This covers not only the offences in the Act, but how to go about evaluating suppliers and mitigating risks within supply chains. Our aim is to raise awareness of the issues and increase informed scrutiny.
In October 2019 we held a firmwide training event on the topic of “Modern Slavery”, which was delivered by an external speaker from the organisation Stronger Together. This provided an overview of the extent of the problem of slavery and human trafficking, both in the UK and globally, and details of the UK government’s response. It also covered how individuals might find themselves in conditions of slavery and helped to raise awareness within the firm of how to recognise the signs.
We held another firmwide training event in March 2020 on “Human smuggling and trafficking: What is the difference and what can we do”. A speaker from the Global Initiative Against Transnational Organized Crime used international case studies to outline the mechanics of the human smuggling industry and how smuggling feeds into the trafficking market in the UK and to consider trends in the UK’s modern slavery landscape.
We try to identify risks to workers in our supply chain by regularly refreshing the due diligence we carry out on our key suppliers before we engage them and through the ongoing supplier management processes we have in place.
When selecting our suppliers, price is not our only driver. We are committed to buying quality products and services from ethical suppliers and part of measuring this involves assessing the approach a potential supplier takes to its people and the workers in its own supply chain. At the start of 2018 we published an internal “Supplier Relationship Management Guide”, which stresses this point, with the next version of this due by the end of 2020.
Covid-19 has heightened the risks of modern slavery in a range of sectors. In recognition of that, in early 2020 we revisited our modern slavery risk mapping across our supply chain to assess where modern slavery was most likely to arise. This assessment considered a range of factors including the jurisdiction of the supplier, their own supply chain, and the business sector. All those suppliers identified as higher risk will be individually approached for discussion and, in some cases where deemed appropriate, an additional audit on this area will be carried out in 2021. The purpose of this is to work with our suppliers and influence their approach positively.
We meet formally with each of our key suppliers at least annually and, among other things, address their approach to slavery and human trafficking at those review meetings. We use contract management software to interrogate our contractual terms (including those dealing with the Act) with suppliers more easily.
In addition, managers responsible for the firm’s relationship with key suppliers visit them at their own premises from time to time, and at times on short notice. This gives us an opportunity to observe first-hand their working conditions and to talk to a sample of their workers direct. In many cases, we have a contractual right to audit the performance and working practices of our suppliers.
Further to our most recent supplier risk mapping exercise, we have committed to assessing and scoring our significant suppliers’ approaches to modern slavery and will begin these assessments as part of our existing annual supplier reviews from the first quarter of 2021. This will allow us to rate their respective performance and seek continual improvement from them.
Our own business initiatives
Code of Business Conduct
Our commitment to fair employment practices in relation to our own employees is embodied in our Code of Business Conduct. This provides information about how we approach our day-to-day activities and the principles in it are covered in inductions for new staff and reinforced through training. The standards in the Code are reflected in our policies and procedures and we endeavour to embed them in everything we do.
UN Global Compact
In April 2019 the firm issued a letter of commitment to the United Nations, confirming that the firm supports the Ten Principles of the United Nations Global Compact on human rights, labour, environment and anti-corruption. This support includes promotion of the Sustainable Development Goals, of which Goal 8 (Decent work and economic growth) is particularly pertinent to the issue of modern slavery.
In July 2020 the firm published its first Communication on Progress report as a signatory to the United Nations Global Compact. The report covers the firm’s work with suppliers, its engagement with clients, its culture and how it supports employees, as well as its carbon reduction ambitions, its pro bono work and support of the community. The firm’s supplier engagement, ethics and culture of integrity are central to ensuring that slavery and human trafficking is not taking place in the firm’s supply chains.
Responsible Business Week
In September 2019 the firm held its first Responsible Business Week, the aim of which was to explore how we might integrate responsible business into business as usual and the strategic and operational decisions we make every day. As part of this week, we publicised the existence of the apps “Safe Car Wash” and “Unseen” as a way of reporting concerns relating to suspected incidents of modern slavery.
Over the next 12 months we will be commencing a roll out of initiatives to drive positive working practices in our supply chain, including on modern slavery, diversity and the environment.
Paul Stacey, Executive Partner
30 October 2020