Transparency in supply chain management
s54 Modern Slavery Act 2015
31 October 2016
The way we do business at Freshfields reflects who we are and what we stand for. We don’t just want to advise our clients well, we want to do so in a responsible and sustainable way. Freshfields is committed to combatting modern slavery in all its forms, and this is an important goal of the firm’s Responsible Business strategy. We expect the same high standards of those we work with.
This statement is made in accordance with section 54 of the Modern Slavery Act 2015 (the Act), and sets out the steps taken in our last financial year throughout our global business to identify and reduce the risk of modern slavery occurring within either our business or supply chains.
Overview of our business
Freshfields Bruckhaus Derringer is a global law firm, operating as a limited liability partnership registered in England and Wales with branches and related undertakings across the world. This statement is published on behalf of Freshfields globally.
In terms of suppliers (including contractors), our top three areas of spend are premises, human resources and IT.
Steps taken during our 2015-16 financial year
Because we are a global business with global supply chains, we adopt the international law definitions of forced labour1 and human trafficking2 as the most apt for framing our response to modern slavery as part of our Responsible Business strategy and fulfilling our responsibilities under the Act. The relevant UK criminal offences are addressed by us accordingly.
This year we have introduced supplier questions which deal specifically with modern slavery.
We have established a working group, reporting to our senior partner and chaired by a partner, comprised of representatives from the following business functions:
- Corporate Responsibility
- Human Resources
- Global Business & Human Rights.
The group also has external members to ensure we have an independent voice and to demonstrate transparency.
This group has been established to carry out the following tasks:
oversee the development of appropriate training for relevant people within the business to raise awareness of modern slavery and of our policies and procedures;
review currently available information about our global business and supply chains relevant to modern slavery issues;
identify and, where practical, address gaps in that information;
using that information, undertake ‘heat mapping’ to establish operations, situations and/or suppliers that represent a particular risk due to their location, industry or other characteristics;
review existing procurement procedures, e.g. supplier questionnaires and codes of conduct, and other relevant internal policies and procedures (e.g., whistleblowing policy) and make recommendations for any appropriate changes;
oversee focused due diligence where potential issues are identified and make recommendations as to how those issues should be dealt with;
capture learning from the group’s work and make recommendations on integrating the lessons learnt into our internal systems and procedures; and
recommend appropriate key performance indicators to be included in future statements.
This statement is authorised and approved by the Senior Partner on behalf of the Freshfields global partnership.
1Article 2, International Labour Organisation Forced Labour Convention 1930; Article 1, Abolition of Forced Labour Convention, 1957
2Article 3, Protocol to Prevent, Suppress and Punish Trafficking in Persons, Supplementing the United Nations Convention Against Transnational Organized Crime (Palermo, 2000)