Modern Slavery Policy

Modern slavery is the severe exploitation of other people for personal or commercial gain and can take various forms, including forced and compulsory labour and human trafficking. It is a crime and a violation of fundamental human rights.

Our firm has a zero tolerance approach to modern slavery and we take steps to identify whether there is any action we need to take to comply with the Modern Slavery Act 2015 or other relevant legislation or guidance.

Risk review

As part of our approach to risk management, and in accordance with our Risk Management Policy, our Risk Manager, Rebecca Freitas, evaluates the extent to which we are required to take any steps under modern slavery legislation.

Having regard to the size and nature of our practice, we have determined that we do not need to take any particular steps to ensure that slavery and human trafficking are not taking place in our own business or within our supply chain. We do not fall within the remit of Section 54 of the Modern Slavery Act 2015, which requires larger commercial organisations that supply goods or services to prepare a Slavery and Human Trafficking Statement for each financial year. In particular, we have reached this decision in light of the following:

• we do not have a total annual turnover equal to or exceeding the amount set by the Secretary of State, currently £36 million
• the complexity of the firm and the types of supply chains in which we are involved do not raise particular levels of risk or exposure.

Our commitments

We are, however, committed to:

• acting ethically and with integrity in all our business relationships and our internal procedures
• being alert to risks, however small
• promoting a culture of awareness and compliance through education and training, and overseeing arrangements for the sharing of information on modern slavery, which may include providing updates to staff members and informing them of relevant guidance
• ensuring all staff members understand their responsibility to be alert and to raise suspicions of incidents of harm, abuse, neglect or exploitation, or any similar concerns
• remaining alert, as part of our Use of External Suppliers procedure, to any suspicions of incidents of harm, abuse, neglect or exploitation, or similar concerns about the direct activities of any suppliers, contractors or other third parties within the extended supply chain. We may terminate a supply arrangement at any time should any instances of modern slavery come to light.

We are fully committed to the highest possible standards of openness, honesty and accountability, and we actively encourage all staff members who have any concerns related to our activities or our supply chains to report them in accordance with our Whistleblowing Policy. We will treat all such disclosures in the strictest confidence and will endeavour to provide advice and guidance on any action to be taken.

Review

Our COLP, Rebecca Freitas, reviews this policy at least annually to verify that it is in effective operation.