For the financial year ending 30 April 2019
Introduction
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 2019 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 has a zero tolerance approach to modern slavery of any kind within our organisation and supply chains. 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 2019
Browne Jacobson 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 94 members. Our head office is based in Nottingham and we also have offices in London, Birmingham, Manchester and Exeter. We currently have 1001 employees, which includes 138 partners. For the financial year ended 30 April 2019 we had an annual turnover of £77.6m.
Our supply chains
We are continually reviewing how we engage the services of our suppliers and monitor them. As a provider of legal services our suppliers support the operation of our business and very broadly fall into the following general categories:
- consumables
- counsel and experts
- employee benefits
- food and beverage
- telecommunications and information technology
- Facilities Management (building services)
- Business Support services (switchboard, off site storage, document production etc.)
Our supply chains are mainly UK based. We identify our suppliers via both risk and value criteria. In terms of risk we identify whether they are low, medium, or a high risk supplier and in terms of value we identify them by commodity, operational, tactical or strategic which subsequently identifies the due diligence and supplier management process to be adopted.
Our policies
As reported in our previous statements, our internal policies, including our Anti Modern Slavery Policy and Whistleblowing Policy, are reviewed annually to ensure our compliance with the Act and appropriate changes are made if there are lessons learnt during the previous year.
Due diligence processes
As part of our due diligence we are introducing specific measures to ensure that our obligations under the Act are passed through our supply chain. These include:
- A commercial review - process to ensure that appropriate contractual provisions are incorporated into new supplier contracts and renewals of existing contracts, which require a supplier to take reasonable steps to ensure that slavery and human trafficking are not taking place in its business or in its supply chains (where applicable).
- A requirement for all new suppliers, and existing suppliers at the time of renewal, to confirm whether or not they have effective procedures and controls in place to ensure that their business and supply chain is free from slavery or human trafficking and they comply with all anti-slavery laws.
- 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.
Risk assessment
As part of our ongoing firm wide risk assessment, we continue to monitor our procurement process via the application of both our procurement policy and our supplier governance policy. The supplier governance policy and due diligence process identifies if the supplier is low, medium or high risk – which is assessed via a number of factors. In addition, as part of the due diligence process ‘red flags’ are raised where responses and information do not comply with our internal policies, ie Modern Slavery statements. In addition we use a risk matrix to assess our risks and maintain a risk register which prioritises business risks.
Measuring effectiveness
We believe that by developing the due diligence process outlined above we have an effective means of identifying whether modern slavery and human trafficking is taking place in any parts of our business or any of our supply chains. We monitor the relationship with our suppliers in accordance with our supplier governance policy which requires an annual review of compliance with our requirements and risks associated with the supplier and their services.
Browne Jacobson is not aware of any incidents of modern slavery or human trafficking during the financial year. In the event of such an event occurring or an allegation being made, the matter will be initially reported to our Risk & Compliance team to determine appropriate action.
Training
Our Anti Modern Slavery Policy applies to all persons working for us or on our behalf in any capacity.
All staff have been made aware of our Anti Modern Slavery Policy and Whistleblowing Policy and these are available on our intranet for all staff to access.
In July 2018 senior managers in our central teams also attended a seminar on modern slavery and human trafficking and how this could affect our firm and our suppliers. They were responsible for sharing relevant parts of the seminar with their teams.
Board approval
We have agreed management responsibility for this statement and our exec has approved and fully supports these initiatives.
Signed by:
Iain Blatherwick, Managing Partner, Designated Member Browne Jacobson LLP
Date: 17 September 2019