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Transparency in supply chains

31 October 2018

Freshfields is committed to combatting modern slavery in all its forms.  This is an important goal of the firm’s Responsible Business strategy. We expect the same high standards of those we work with.

We have been a supporter of the United Nations Global Compact since 2009, and within our sphere of influence and in our role as professional advisors are committed to supporting and enacting values in the areas of human rights, labour standards, the environment and anti-corruption, as key elements of our Responsible Business strategy. 

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 (1 May 2017 – 30 April 2018) 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 Deringer is a global law firm, operating as a limited liability partnership registered in England and Wales with branches and related undertakings across the world.  The world’s biggest international organisations rely on us to help them make the right decisions in a fast-changing world.  We combine the knowledge, experience and energy of the whole firm to solve our clients’ most complex challenges, wherever and whenever they arise.  This statement is published on behalf of Freshfields globally.

Freshfields has 28 offices and nearly 5,000 partners and staff  worldwide, including approximately 2,300 in Continental Europe, over 1,750 in the UK, 400 in Asia, 300 in the US and 75 in the Middle East and North Africa.

Our top three areas of spend with suppliers (including contractors) are premises and facilities management, human resources / services and technology.  Freshfields’ spend is centred in the UK and Germany – both in terms of the location of our contract manager and the location of our first-tier suppliers – with smaller local agreements at the level of each office. Our spend is highly concentrated with large suppliers such as CBRE, Alexander Mann, Reed & McKay and Overbury plc.  

Our approach to modern slavery

As an international business with global supply chains, we adopt the international law definitions of forced labour [1] and human trafficking [2] to frame our response to modern slavery as part of our Responsible Business strategy and in fulfilling our responsibilities under the Act.  Relevant national criminal offences are addressed by us accordingly.

We continue to direct our efforts with regard to modern slavery through a working group, reporting to our senior partner and chaired by the partner responsible for Global Business and Human Rights within the firm, comprised of representatives from the following business functions:

  • Procurement;
  • Risk and professional ethics;
  • Responsible Business;
  • Human Resources; and
  • Global Business & Human Rights.

The group also has two external members from the NGO community experienced in Modern Slavery and human rights to ensure an independent and challenging voice and support transparency.

This group has been established to carry out the following tasks:

  • oversee the development of appropriate training for people within the business and 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, including through supplier questionnaires and codes of conduct, and other relevant internal policies and procedures (such as our whistleblowing policy) and make recommendations for any appropriate changes;
  • oversee focused due diligence where potential issues may be 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.

Steps taken during our 2017-18 financial year

Our working group continued to meet during the 2017-18 financial year.

As members of the UN Global Compact UK Network’s working group on modern slavery, we participated in their “peer review” process alongside other businesses.

Our internal whistleblowing policy encourages anyone who suspects wrongdoing, including modern slavery abuses, to report it as soon as possible, in the knowledge that concerns will be taken seriously and investigated as appropriate.

We further updated the firm’s procurement terms and commitments, including our Responsible Business Procurement Guidelines.

Having overseen an initial “heat mapping” exercise – taking into account factors including jurisdiction, category of spend and length of supply chain – the working group identified three areas in which it would oversee the carrying out of further, detailed due diligence in relation to modern slavery in our supply chains on a pilot basis.  These areas were in one of each of the following prioritised categories:

  1. On-site personnel (not directly employed);
  2. Off-site personnel (not directly employed); and
  3. Products procurement.

The group oversaw the development of a pilot due diligence action plan, and worked with our procurement team to ensure the individual suppliers identified were contacted directly with targeted questions.  The group reviewed the first responses and agreed follow up actions.  Our intention is to enter wherever possible into a constructive dialogue with suppliers as this project proceeds.

The firm has maintained its global business and human rights and modern slavery toolkits that are designed to provide our lawyers with the practical resources that they need to advise our clients on human rights and modern slavery issues.  A training programme has been created to assist our lawyers in understanding how these issues might arise in our clients’ businesses, including their global supply chains and how our clients can respond to these issues.  This training has been provided to our lawyers on a global basis with in-depth region-specific sessions in Asia, the Middle East and the US, as well as in the UK and our other European offices.

We have continued to provide information and training on modern slavery issues to our clients, both in conference format and in individual sessions.

Through our pro bono practice we continue to act directly for victims of human trafficking, winning the Law Society of England & Wales’ “excellence in pro bono” award this year for our work in this area.

This statement is authorised and approved by the Senior Partner on behalf of the Freshfields global partnership.

 

Edward Braham
Senior Partner

 

Signatories

This statement has been signed by representatives of Freshfields worldwide to reflect the firm’s commitment to global working and our responsible business strategy


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)