For the financial year ending 30 April 2017
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 2017 to ensure modern slavery and human trafficking is not taking place in any part of our business or any of our supply chains.
Browne Jacobson LLP published its first Modern Slavery statement in October 2016 and in the past year we have continued to increase our work on Modern Slavery and strengthening our understanding of risk.
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 this year. We remain 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 2017
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 92 members. Our head office is based in Nottingham and we also have offices in London, Birmingham, Manchester and Exeter. We currently have 936 employees, which includes 133 partners. For the financial year ended 30 April 2017 we had an annual turnover of £66.9m.
As reported in our previous statement, our internal policies were reviewed to ensure our compliance with the Act, which included our Anti Modern Slavery Policy and Whistleblowing Policy.
Our 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
In the financial year ending 30 April 2017 we established a dedicated project resource to review procurement/external supplier management generally.
We have reviewed our supplier risk assessment process to cover the entire scope of our business, encompassing operational, commodity, strategic and tactical suppliers. This risk categorisation exercise is based on a number of identified risks to our business, of which modern slavery is one. These categories have been documented in a new Procurement Policy. The Procurement Policy states the minimum requirements to which suppliers must work; this includes a requirement that they comply (if applicable) with the following legislation; Minimum Wage Act, Modern Slavery Act, Equality Act, Health and Safety at Work Etc. Act, Data Protection Act.
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.
Our future plans include:
- monitoring responses from suppliers and using this to shape our future due diligence processes that are put in place regarding our supply chains
- continuing with our wider review of our procurement process
- continuing to provide advice to and work with our clients on how to eradicate the risk of modern slavery and human trafficking in their businesses and supply chains
- developing a process to ensure that appropriate contractual provisions are incorporated into new supplier contracts and renewals of existing contracts, which require a supplier to take steps to ensure that slavery and human trafficking are not taking place in its business or in its supply chains.
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 2017.
Browne Jacobson LLP
24 October 2017