We make the statement below in compliance with section 54(1) of the Modern Slavery Act 2015 (the Act).
This statement is for our financial year ending 31 March 2019.
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We are committed to practices that respect human rights in all of our business dealings.
As at 31 March 2019, we had 774 people working with us made up of self-employed partners, employed lawyers, employed support staff and administrative staff contracted by us from third parties.
All of our employees receive the statutory employment rights to which they are entitled and our human resources department ensures all of our employees have the legal right to work in the UK. Our employees are provided with safe working conditions and we have the expectation that they will be treated at all times with dignity and respect.
We are committed to fair employment practices and have achieved accreditation as a Living Wage Employer.
Our ongoing ‘Pennwell’ wellbeing programme promotes the importance of welfare both at home and in the workplace, providing access to tools, information and support networks to improve the mental, physical and financial wellbeing of our staff.
Our ‘Pennclusion’ diversity and inclusion programme seeks to ensure that the firm is a truly inclusive business, with a workplace culture that enables all colleagues to thrive regardless of background or personal circumstances.
We have a procurement process in place that seeks to manage risk and deliver value for the firm from the money spent. The process is designed to strike a balance so that higher risk, higher cost procurement undergoes greater scrutiny without creating an onerous burden on smaller suppliers to win our business.
All of our suppliers are required to meet minimum standards. Where appropriate, our tender process is generally designed to prefer those who have Living Wage Foundation accreditation or other accreditations that demonstrate a commitment to ethical practices. We insist that suppliers pay their staff the Living Wage where their staff will be working in our offices for more than two hours a day, any day of the week.
During 2018, we undertook an audit of our cleaning service provider. The objective of our audit was to ensure that its cleaners have the right to work in the UK, have not paid or are indebted for a recruitment fee linked to their employment, have not had their passport retained, have a written contract of employment, are paid in line with at least the national minimum wage requirements, have access to a grievance procedure and have received relevant health and safety training. When required, reputable sub-contractors must be used.
The audit included a review of documentation and interviews with those who attend to clean our offices. No indication was found of anything untoward relating to their employment, working conditions or level of pay.
Our assessment is that our business activities do not pose a high risk of modern slavery.
In terms of our supply chain, we regard the risk factors to be territorial and whether a supplier is a significant supplier of people. In 2018 we concluded that our cleaning supplier is a high risk supplier and that is why we performed that audit. Our modern slavery procedures will continue to be risk based in this manner, with our attention focused on areas of higher risk. Looking ahead to 2020, work will focus on integrating the procurement processes within the enlarged firm following the completion of the merger to form Penningtons Manches Cooper LLP in July 2019. That integration work will identify any high risk suppliers that need auditing.
We conduct a face to face induction for employees which includes an outline of our modern slavery prevention objectives. Additionally, all new starters are required to complete an e-learning module outlining the Modern Slavery Act 2015 and their duties under it as a worker at the firm. Employees cannot pass their probation without successfully completing the training module.
Staff are told that they should report any concerns about the treatment of others to the risk team.
In addition, all staff are required to complete an e-learning module that sets out the impact of modern slavery and the part we all play in its prevention.
Our whistleblowing policy promotes the reporting of modern slavery concerns and provides protection for any employees that do so. Employees are informed of the policy at induction and the policy is accessible to staff at any time via our intranet.
We take compliance with law and regulation seriously and have a dedicated risk and compliance team for that purpose. Tim Palmer is the partner responsible for the firm’s risk management and compliance and our Compliance Officer for the purposes of our regulator. He and his team are responsible for monitoring the firm’s compliance with law and regulation and are also responsible for reporting to external authorities where appropriate. To achieve this, the team promotes a culture where all staff are encouraged to report anything that concerns them.
The risk and compliance team is accountable for audit and reporting relating to our compliance with section 54 of the Act. The policies and procedures adopted by this firm to achieve compliance with section 54 of the Act, as detailed above, are:
The risk and compliance team will be responsible for reviewing whether these policies are achieving the aims of section 54 of the Act and developing further policies, training and guidance where needed.
This statement has been approved by the firm’s management, who will review and update it annually.