For the financial year ending 30 April 2022
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 2022 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 and the effectiveness of such steps.
Our structure and business as at 30 April 2021
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 67 members. Our head office is based in Nottingham and we also have offices in London, Birmingham, Manchester and Exeter. We currently have 1077 employees, which includes 132 partners. For the financial year ended 30 April 2022 we had an annual turnover of £94m.
Our supply chains
Our supply chain covers the procurement of goods and services to support the operations of our business and services to our clients. These fall into the following categories:
- IT – hardware, software and infrastructure, including hosting;
- Employee benefits;
- Building services including cleaning, security and other facilities management;
- Business support services including document production and storage;
- Recruitment agencies;
- Professional services including barristers, medical professionals and various consultants and experts.
The majority of our suppliers and supply chains are UK based
Our relevant internal policies are:
- Anti-Modern Slavery;
- Whistleblowing; and
These policies are available to everyone across our business on our intranet. Each is reviewed annually and updated if necessary, to ensure continued compliance with the Act and to capture any learnings from the previous year.
Due diligence processes
We are in the process of overhauling our supplier due diligence process. The new process, which is due to be rolled out in July 2022 will require the requestor to complete a risk assessment at the commencement of each new supplier engagement. The initial risk assessment includes the following three questions:
- Is the supplier based, or performing services outside of the UK, EU, Scandinavia or North America?
- Does the supplier utilise material amounts of unskilled labour?
- Is the supplier providing any of the following services? Manufacturing, food processing, warehousing, security services, cleaning or construction.
All new suppliers are required to complete a supplier questionnaire before being appointed. The content of the questionnaire presented to the supplier in relation to modern slavery depends on the answers to the risk assessment questions:
Baseline modern slavery due diligence
If the answer to all of the above questions is no, the supplier will be asked to provide (i) a link to their modern slavery statement (if applicable); and (ii) an overview of their approach to assessing and monitoring the risk of modern slavery within their supply chain.
Enhanced modern slavery due diligence
If the answer to any of the above questions if yes, additional due diligence will be performed. The supplier will be required to provide more information regarding actions taken to check for modern slavery and to provide a copy of their modern slavery policy.
During the due diligence process, the answers and information provided will be reviewed by our Risk and Compliance team and any risks will be communicated to the relevant head of department, director or partner via a due diligence summary. Each of the risks outlined in the due diligence summary are graded red, amber or green. A red grading cannot be accepted by the relevant head of department etc. but will be escalated to our Risk and Compliance Committee.
At the end of each financial year, a report is prepared by our Procurement Manager and Risk and Compliance team and presented to our Exec board. This report summarises our assessment of the risk of modern slavery within our business and supply chains and outlines the actions we have taken and the recommendations for the forthcoming financial year to continue improving transparency and awareness.
On consideration of the nature of our business and supply chains, we consider that the overall risk of modern slavery is very low but focus on this subject at board level further underlines our commitment to ensuring that this heinous act is not taking place in any part of our business or supply chains.
Although we undertake at least baseline modern slavery due diligence on all of our suppliers, the elements of our supply chains which are most at risk of modern slavery are within our building services category. We work closely with those suppliers to understand the steps they take to assess and manage the risk of modern slavery. For example, our Facilities Management supplier has provided us with details of their recruitment practices, including their process for selecting and managing recruitment agencies.
Our tracking and current due diligence processes ensure that all supplier engagements go through the appropriate due diligence and approval. The introduction of our updated due diligence process will further enhance the efficiency of this process.
During the financial year covered by this statement, we are not aware of any incidents or allegations of modern slavery, nor any specific risks or concerns regarding any element of our supply chains.
Building on the modern slavery training delivered during 2021, we have set up a cross-functional group which meets quarterly to discuss risks and actions and to determine any additional steps we could take. The group will disseminate the information within their teams in order to (i) increase awareness and knowledge; and (ii) ensure that modern slavery is routinely discussed.
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: 29 June 2022
Modern slavery statements
Risk & Compliance Director
Mandy is the Risk &Compliance Director and manages the team responsible for all aspects of risk and compliance within the firm.
+44 (0)115 976 6179