Slavery and Human Trafficking Statement
Farrer & Co LLP takes the issue of modern slavery, as defined in the Modern Slavery Act 2015, seriously. We consider that the likelihood of an incidence of modern slavery in our business or our supply chains is low. However, we are committed to improving our practices in investigating and ensuring that slavery and human trafficking do not take place in any of our supply chains and in any part of our business.
2. Our firm and business
We are an English law firm with offices in London providing a range of English law services to individuals, families & trustees, charities & institutions and businesses in the UK and more widely across a number of sectors. We have a total of over 400 partners, fee-earners, support staff and business services staff. To ensure the provision of such legal services in a cost-effective manner to our client, it is a commercial necessity for us to use third party service providers.
3. Our policy in relation to slavery and human trafficking
The firm's Modern Slavery Policy was launched internally and externally in September 2016 and remains on our intranet as well as our website. Our Slavery and Human Trafficking Statement was published at the same time.
We want to be sure as much as we can that slavery and human trafficking is not taking place anywhere in our supply chain. Our Modern Slavery Policy and draft Procurement and Outsourced Services Provider Policy (see section 4 below) reflect that commitment These Policies sit alongside our Outsourcing, Whistleblowing, Corporate Responsibility, Equality & Diversity, Health & Safety and Anti-Bribery & Corruption Policies and our London Living Wage Accreditation.
4. Our due diligence processes in relation to our business and our suppliers
In the last financial year we identified over 3,000 suppliers of services which had been used or were being used and those suppliers are primarily located in the UK but may have offices and staff based overseas. Those suppliers included office services providers, website administrators and experts.
A Procurement and Outsourced Services Provider Policy ("Procurement Policy"), currently in draft, will be approved by our Management Board in Autumn 2017. This draft Policy applies to all Partners and members of staff who are responsible for procuring goods or services for the firm and is likely to be particularly relevant to our Business Services Directors (Finance & Risk, Human Resources, Marketing & Business Development, Knowledge, Learning & Development and IT). Its aims are:
- to ensure that, as far as is possible, services are procured from all third party providers through a process which is transparent, non-discriminatory and proportionate to the circumstances and requirements of each purchase; and
- that we comply with our various regulatory and legal obligations, as listed in its Schedules, including with issues including modern slavery, prevention of child labour and ensuring that our Living Wage Employer commitment extends to our suppliers and all of their employees.
Our Chief Financial Officer has the responsibility of reviewing the Procurement Policy annually to ensure it complies with our legal and ethical obligations, and to verify that it is in effective operation across the firm. Our Business Services Directors have primary and day-to-day responsibility for implementing the Procurement Policy. Our Partners are responsible for ensuring that those members of staff reporting to them are made aware of and understand the Procurement Policy and are given adequate and regular training on it. All staff are welcome to comment on the Procurement Policy and suggest ways in which it might be improved.
5. Risk monitoring and compliance
We have a dedicated Risk & Compliance team responsible for overseeing the due diligence above as well as progressing our obligations under the Modern Slavery Act 2015 and other legislation applying to this firm. The team works closely with our Business Service Directors and other key stakeholders involved in our procurement programme to enforce compliance with our Modern Slavery Policy and to ensure that it is in effective operation within the firm.
6. Firm wide training
To ensure a high level of awareness and understanding of the risks of modern slavery and human trafficking in our supply chains and our business, our Business Services Directors and those other members of staff closely involved in the procurement process have been guided through the Modern Slavery Policy and draft Procurement Policy and will receive specific training on such matters.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Farrer & Co LLP's slavery and human trafficking statement for the financial year ending 30 April 2017.
Simon Pring, Partner and member of the Management Board
on behalf of the Members of Farrer & Co LLP
31 October 2017