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 2020.
Clyde & Co is a limited liability partnership registered in England and Wales with registered number OC326539 and registered office of The St Botolph Building, 138 Houndsditch, London, EC3A 7AR, United Kingdom. It is a law firm authorised and regulated by the Solicitors Regulation Authority of England and Wales. Outside the UK, Clyde & Co has branches in France, Qatar and the UAE.
Clyde & Co is a dynamic, rapidly expanding global law firm focused on providing a complete legal service to clients in our core sectors.
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 our relationships.
Clyde & Co is a signatory to the United Nations ("UN") Global Compact. This is a global initiative that calls upon companies to align their strategies and operations with universal principles on human rights, labour, environment and anti-corruption, and take actions that advance societal goals. As a signatory, we produce an annual Corporate Responsibility and Inclusion Report that sets out how the principles of the UN Global Compact are integrated across our business environment, including principles one ("the protection of internationally proclaimed human rights") and four ("the elimination of all forms of forced and compulsory labour").
We consider Clyde & Co 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 set out below.
We apply the highest possible standards in the recruitment and employment of our people. We conduct due diligence on our prospective employees prior to them joining Clyde & Co. When recruiting, we comply with all local employment legislation and any applicable regulations.
All of our staff are expected to comply with relevant laws and professional codes of conduct, as well as Clyde & Co's internal Anti-Slavery and Human Trafficking Policy, Whistleblowing Policy, and other policies and procedures.
We are an Accredited Living Wage Employer, meaning that we have committed to pay all of our employees a fair living wage. This commitment is also extended to contractors of the firm.
We organise online training on modern slavery that must be completed by key individuals globally who we have identified as dealing with any aspect of procurement on behalf of Clyde & Co. The Firm-wide anti-slavery and human trafficking policy forms part of the induction pack that is given to employees when they join the Firm, and regular training is provided as necessary.
Clyde & Co has long-term relationships with many of the businesses it engages to run its premises, such as catering, hospitality, transport and cleaning providers. Clyde & Co does not make any demands of such suppliers that may lead them to violating laws, including modern slavery and encourage them to improve their own compliance with anti-slavery laws. By way of example, we require suppliers to pay their employees who work in our London offices a salary which is at least equivalent to the London Living Wage.
The majority of our suppliers are based in the UK and supply standard goods or services that are low-risk for modern slavery. In addition, we aim to hold monthly supplier relationship management meetings and regular service reviews with core suppliers, at which risk concerns are raised and addressed.
We perform vetting and due diligence by way of risk assessments on our larger suppliers by spend and those that we consider to be higher risk. In addition, we have a due-diligence portal which will increasingly be used to screen suppliers on a number of issues, including modern slavery. With regard to existing suppliers of goods and services to our London office, our due diligence has not identified any occurrence of modern slavery. We also require such suppliers to carry out due diligence on their own suppliers. We are extending these due diligence processes to our other offices.
We have pro-forma supplier contracts which we are increasingly using for companies that directly supply Clyde & Co. These pro-forma contracts incorporate provisions requiring the supplier to:
We have a pro-forma letter of engagement for instructing a third party professional, such as an expert or a foreign lawyer. In this pro-forma letter, we require the third party professional to warrant that they comply with labour, anti-slavery and human trafficking laws, including but not limited to the UK Modern Slavery Act, and that any subcontractor used by the third party professional in relation to the engagement does likewise.
Approved and signed by
Michael Swangard, Designated Member
For Clyde & Co LLP