For the financial year ending 30 April 2016
This statement has been published in accordance with the requirements of section 54(1) Modern Slavery Act 2015 (the Act). It sets out the steps taken by Browne Jacobson LLP during the financial year ended 30 April 2016 (and an update on some steps take since that date) to ensure modern slavery and human trafficking is not taking place in any part of our business or any of our supply chains.
Modern slavery is a term used to encapsulate the crimes of slavery, servitude, forced or compulsory labour and human trafficking.
Browne Jacobson LLP has a zero tolerance approach to modern slavery of any kind within our organisation and supply chains. We do not believe any incidences of modern slavery took place within our business in the year. We are committed to improving our practices to enable us to identify and eradicate any modern slavery within our supply chains.
Our structure and business as at 30 April 2016
Browne Jacobson LLP is a national law firm supplying legal services, advising clients across the private and public sectors. We are a limited liability partnership registered in England and Wales (registered number OC306448). We are owned by our 74 members. Our head office is based in Nottingham and we also have offices in London, Birmingham, Manchester and Exeter. We currently have over 749 employees, which includes 104 partners. For the financial year ended 30 April 2016 we had an annual turnover of £63m.
Since the year end we have completed a review of our internal policies to ensure our compliance with the Act and as part of this exercise a standalone Anti Modern Slavery Policy has been adopted which reflects our commitment to implementing and enforcing effective practices and controls to ensure modern slavery is not taking place in our business and supply chains. We support openness about raising any concerns of human rights violations like modern slavery and our Whistleblowing Policy encourages staff to report genuine concerns about wrongdoing or legal breaches – this policy has been specifically reviewed to ensure it adequately covers modern slavery and human trafficking concerns.
Over the course of the last twelve months, Browne Jacobson has raised awareness about the Act initially amongst senior management of the organisation – in particular at Operations Board and Risk and Compliance Committee level within the firm.
Our new Anti Modern Slavery Policy applies to all persons working for us or on our behalf in any capacity. All managers dealing with those most at risk of encountering modern slavery issues, such as those working in the areas of procurement and business operations, must ensure those individuals reporting to them understand and comply with our Anti Modern Slavery Policy.
Our supply chains
As a provider of legal services our suppliers support the operation of our business and very broadly fall into the following general categories:
- counsel and experts
- employee benefits
- food and beverage
- telecommunications and information technology
We have recently carried out an exercise to identify all of our suppliers and are currently categorising these suppliers on the basis of risk to inform our future actions. This risk categorisation exercise is based on a number of identified risks to our business, of which modern slavery is one. We will also be reviewing our expectations of suppliers in areas such as data protection/information security, diversity and ethical, social, environment, health and safety issues.
Once this categorisation exercise is complete, the results will shape our future due diligence processes around our supply chains and we will focus our efforts on the main areas of concern that have been identified and adapt our approach based on these findings.
A wider plan looking at how we can enhance our own procurement processes has already been considered at Operations Board level, and the work we are doing around compliance with the Act will also form part of this broader approach. Going forward, as a minimum we will be seeking reassurance from relevant suppliers on their compliance with the legislation.
Browne Jacobson LLP has not been informed of any incidents of modern slavery or human trafficking during the financial year, but would investigate any allegations should they arise and take appropriate action in accordance with our policies and procedures. In the event of such an event occurring or an allegation being made, the matter will be initially reported to our Risk and Compliance team to determine appropriate action.
As noted above, our immediately identified actions are as follows:
- complete our exercise categorising our suppliers based on various risk factors (including modern slavery) and use this to shape our future due diligence processes that are put in place regarding our supply chains;
- provide internal briefings to raise awareness about the Act and how to mitigate the risks of modern slavery and ensure those most at risk of encountering modern slavery issues have received guidance on our Anti Modern Slavery Policy; and
- continue with our wider review of our procurement process.
This statement is made in accordance with the Modern Slavery Act 2015 section 54(1) and constitutes our slavery and human trafficking statement for the financial year ending 30 April 2016.
Browne Jacobson LLP
7 October 2016