Slavery and Human Trafficking Statement - Financial Year Ending 30 April 2017
This slavery and human trafficking statement is made on behalf of Clyde & Co LLP, ("Clyde & Co"), pursuant to section 54 of the Modern Slavery Act 2015 (the "Act") for the financial year ending on 30 April 2017.
Clyde & Co LLP is a limited liability partnership registered in England and Wales with registered number OC326539. It is a law firm authorised and regulated by the Solicitors Regulation Authority of England and Wales ("SRA").
Details of Clyde & Co's organisational structure and its office locations can be found on the firm's website - Legal Notices.
Clyde & Co has a zero-tolerance approach towards any form of slavery, servitude, forced or bonded labour, or human trafficking (collectively referred to as 'modern slavery' in this statement). We will not support any arrangement or relationship that is knowingly involved in modern slavery. We are committed to ensuring that there is no modern slavery in our business or in our supply chains, and to acting ethically and with integrity in all of our relationships.
Our practices in relation to combating modern slavery
We consider the firm itself to be relatively low risk in relation to modern slavery, given the sector in which we operate. Our current practices in relation to combating modern slavery are as follows:
In respect of our supply chains, we expect and require all of our suppliers to comply with all local, national and (where applicable) international laws and regulations.
In respect of our ongoing commitment to supplier due diligence, some of our suppliers have been screened using a new supplier due diligence portal, which includes a dedicated section of questions focused on modern slavery. We are continuing to add more of our suppliers to this system as soon as practicable.
We have a clear Whistleblowing Policy that applies to all partners, members, employees, contractors and all other individuals working for the firm. This policy is published on our Intranet site. If there are any genuine concerns about any wrongdoing or breaches of the law, including modern slavery laws, these concerns can be raised in confidence and without fear of disciplinary action.
Finally, the firm has an anti-slavery and human trafficking policy which is located on the firm's Intranet. The policy prohibits modern slavery and applies to all partners and employees.
Steps we will be taking to combat modern slavery in the 2017-2018 financial year
To enhance our commitment to the prevention of modern slavery, we will be progressing the following initiatives during the 2017-2018 financial year:
- Rolling out online training on modern slavery, which will be made available to all of our employees and partners globally in order to increase firm-wide awareness of the issue. In the first instance, training will be focused on the UK and on those staff involved in procurement and risk management;
- Continuing to add more of our suppliers to our new supplier due diligence portal, which includes a dedicated section of questions focused on modern slavery;
- Centralising and taking steps to improve our procurement procedures and processes to ensure that our obligations under the Act are passed through to our supply chain;
- Where practicable and appropriate, incorporating adequate anti-modern slavery provisions in new supplier contracts or in those supplier contracts that are up for renewal;
- Commencing a risk assessment of Clyde & Co's suppliers, identifying and prioritising those suppliers which present the highest risk in relation to modern slavery; and
- Conducting an evaluation of our global recruitment procedures and producing a list of recommendations in respect of any improvements needed.
This statement will be reviewed annually and made available on our website.
This statement was approved by the firm's board on 6 September 2017.
Simon Konsta, Designated Member
CLYDE & CO LLP