For the financial year ending 30 April 2020
We will publish our modern slavery statement for the financial year to 30 April 2021 by the end of October 2021 in line with the Modern Slavery Act 2015.
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 2020 to ensure modern slavery and human trafficking, collectively referred to as “modern slavery” in this statement, is not taking place in any part of our business or any of our supply chains.
Browne Jacobson has an unwavering approach to tackling 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 firm and supply chains.
Our structure and business as at 30 April 2020
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 93 members. Our head office is based in Nottingham and we also have offices in London, Birmingham, Manchester and Exeter. We currently have 988 employees, which includes 114 partners. For the financial year ended 30 April 2020 we had an annual turnover of £80.5m.
As a result of the COVID-19 pandemic, the majority of our partners and employees have been working remotely from home since March/April 2020 and continue to do so as at the date of this statement.
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:
- 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.
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 processes we now require a declaration from all new suppliers that they comply with applicable legislation in relation to modern slavery. We are also currently making improvements to our supplier questionnaire.
We will also be introducing specific measures to ensure that our obligations under the Act are passed through our supply chain, these new measures include:
- a commercial review for non-commodity contracts 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 modern slavery is not taking place in its business or in its supply chains (where applicable).
- continuing to provide advice to and work with our clients on how to eradicate the risk of modern slavery in their businesses and supply chains.
We also plan to recruit a Procurement Manager during the course of the 2020-21 financial year to oversee our complete procurement processes. At the present time a Project Lead and former senior equity partner of the firm are taking responsibility for this.
As part of our ongoing firm wide risk assessment, we continue to monitor our procurement process via the application of our procurement policy. The 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, i.e. Modern Slavery statements. In addition, we use a risk matrix to assess our risks and maintain a risk register which prioritises business risks.
In recent weeks our risk assessment processes have been reconsidered by our Risk and Compliance Committee and Exec in light of the likely impact of the COVID-19 pandemic on our business risks and taking into account the Home Office guidance on modern slavery reporting during the coronavirus (COVID-19) pandemic published on 20 April 2020. At this time our current approach is considered to be sufficient, but we are keeping this under review.
We believe that by developing the due diligence process outlined above we will have an effective means of identifying whether modern slavery is taking place in any parts of our business or any of our supply chains. We are also developing improvements to how we monitor the relationship with our suppliers.
Browne Jacobson is not aware of any incidents of modern slavery 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.
Our Anti Modern Slavery Policy applies to all persons working for us or on our behalf in any capacity. Our Anti Modern Slavery Policy and Whistleblowing Policy are available on our intranet for all staff to access. Our Anti-Money Laundering training will be updated to include areas of cross over with Anti Modern Slavery.
We have agreed management responsibility for this statement and our exec has approved and fully supports these initiatives.
Richard Medd, Managing Partner, Designated Member Browne Jacobson LLP
Date: 26 June 2020