Modern Slavery Act Statement 2022
This statement is made on behalf of Slater and Gordon UK Holdings Limited pursuant to Section 54(1) of the Modern Slavery Act 2015 (“the Act”) and it constitutes our Modern Slavery Statement for all entities within the Slater and Gordon owned group of companies (“the group”).
Slater and Gordon UK Holdings Limited have produced this group statement setting out how we will prevent modern slavery in our qualifying companies (detailed below) together with all other group companies which follow the same principles. A group wide approach has been adopted to pro-actively manage and prevent modern slavery.
Slater and Gordon as a group is committed to identifying and understanding modern slavery risks and to ensuring the prevention of modern slavery practices across the group and its various supply chains. We will endeavour to ensure that with proactive processes and training, all employees, agents, consultants, suppliers, and any other parties associated with the group will be safeguarded, treated fairly and with dignity.
The Slater and Gordon group comprises of a number of separately constituted and regulated legal entities providing legal, motor, and financial planning services in England, Wales, Malta, and Scotland.
The end of the financial year for all group companies was 31st December 2020 and within the Group structure the following legal services and group management support service businesses, met the qualifying criteria under the Act.
- Slater and Gordon UK Holdings Limited (10977311)
- Slater and Gordon UK 1 Limited (07895497)
- Slater and Gordon UK Limited, (07931918)
None of the other group owned and operated companies within the group individually met the qualifying criteria under the Act for a Modern Slavery Statement but do still fall within the overall group policy and strategy.
Areas of risk and our approach
Our principal areas of risk across the Group are within people supply chains and recruitment through agencies.
At Slater and Gordon, we are in the process of establishing systems and controls to enable effective management of all supplier relationships and this is a key area for continuous improvement.
As part of a pre-contract checklist, we ask all potential new business partners to confirm their compliance with the Act and the steps they specifically take to satisfy themselves that slavery and human trafficking is not taking place in any of their supply chains or any other part of their business.
We now include clauses in the contracts we enter into with commercial business partners which provide for compliance with the Act.
The recruitment of new colleagues into the group uses reputable recruitment agencies which are subject to a thorough verification process prior to their addition to our approved list of recruitment agencies Whilst the recruitment of legal and other professional colleagues is seen as being of low risk in terms of slavery or human trafficking there will be a review during 2022 of our relationships with suppliers which will include the reinforcement of the groups Anti-Slavery Policy and the introduction of a modern slavery clause into all recruitment contracts.
Our Group wide Anti-Slavery Policy was last updated in 2020 to embed our zero-tolerance approach to modern slavery and to reflect our commitment to acting ethically and with integrity in all our business relationships.
All colleagues within the Group are responsible for the detection and reporting of any modern slavery practices. Modern slavery awareness training is embedded into our induction process for new starting colleagues and is updated during the course of the year to other colleagues.
Specific modern slavery awareness training is provided to those colleagues directly involved in the management of supply chains or the procurement of supplier services to ensure they have the requisite tools and knowledge to deal with any identified concerns. The most recent training was delivered to all employees in December 2021.
Concerns or suspicions are to be reported either to the Group’s Legal, Data & Compliance team or to the Human Resources team using our new dedicated online portal, or by using our Whistleblowing Policy and Whistleblowing Procedure.
This is our third annual Group statement. The previous statement also covered the same qualifying Group entities.
The main activities over the preceding 12 months have been the introduction of mandatory training not just to those employees who might be directly engaged with the risks of modern slavery but to every employee in the Group.
We have also continued with the review of supply chains to include specific procedures and protocols for the verification of new suppliers into Group businesses, which allows for enhanced risk management and robust control over supplier onboarding and performance management.
Where applicable new supply contracts entered into by the business will include modern slavery provisions, which will be used to evaluate risks and supplier performance issues to identify high risk areas. This will be subject to continuing review during 2022.
Delivery of these systems and controls rest with our Legal and Human Resources teams. The Legal team includes a member of the Chartered Institute of Procurement and Supply which support the requisite skills and knowledge to build best practice procurement standards which are sustainable and ethical across the Group.
The Modern Slavery Statement has been approved by the Board of Directors who will review and update it regularly.
Dated: 31st January 2022