Transparency in supply chains
31 October 2017
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 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. This statement is published on behalf of Freshfields globally.
Our top three areas of spend with suppliers (including contractors) are premises, human resources / services and IT.
Our approach to modern slavery
As an international business with global supply chains, we adopt the international law definitions of forced labour  and human trafficking  to frame our response to modern slavery as part of our Responsible Business strategy and in fulfilling our responsibilities under the Act. Relevant UK 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:
- Risk and professional ethics
- Responsible Business
- Human Resources
- 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 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, 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 2016-17 financial year
Our working group met three times during the 2016-17 financial year.
The working group obtained and reviewed information available concerning our global business and supply chains.
The working group planned and oversaw an initial “heat mapping” exercise to prioritise areas of our global business and supply chains for further, detailed due diligence. In doing so key factors considered included location, sector, length of supply chain, type of product or service and publicly available data on areas of sensitivity regarding modern slavery.
The group identified three areas in which it would oversee the carrying out of further, detailed due diligence on a pilot basis:
1. On-site personnel (not directly employed)
2. Off-site personnel (not directly employed)
3. Products procurement
The firm developed 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.
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)