This Statement is made on behalf of Slater and Gordon UK Limited (‘‘the Company’) pursuant to section 54(1) of the Modern Slavery Act 2015 (“the Act”) and constitutes our slavery and human trafficking statement.
The Company is committed to preventing acts of modern slavery and human trafficking from occurring within both its business and supply chain, and seeks to partner with suppliers that uphold the same standards.
The Company embraces a diverse and safe workplace environment in which equal opportunity and fairness are paramount.
Structure and business
The Company is a private limited company registered in England and Wales (07931918) providing specialist legal and complementary services and is authorised and regulated by the Solicitors Regulation Authority (591058) and by the Financial Conduct Authority (579176) for insurance mediation activity. The Company is a wholly-owned subsidiary of Slater & Gordon (UK) 1 Limited, whose ultimate parent entity is Slater and Gordon UK Holdings Limited.
The nature of the Company’s business means that its supply chains are relatively limited in number, and therefore the risk of modern slavery within the business is deemed to be low.
As a legal business, the Company works to professional standards and complies with all laws, regulations and relevant rules.. All members of staff are required to operate in accordance with the Code of Conduct, the Company’s policies, procedures and National Practice Standards. The Company works to deliver the best outcome for those people who work within the Company and promotes working with people in a way that is open, respectful and supportive.
The Anti-Slavery Policy reflects the Company’s commitment to acting ethically and with integrity in all business relationships. The Company expects the same high standards from those who work within the Company and is committed to ensuring that there is no modern slavery or human trafficking in the Company’s supply chains or in any part of the Company.
The prevention, detection and reporting of modern slavery is the responsibility of all those working for the Company and associated companies within the Slater & Gordon Group. The Company also has a Whistle Blowing Policy (published on the intranet site) which encourages staff members and others to raise concerns about anything that is unlawful or amounts to improper conduct and seeks to ensure matters can be raised in confidence without fear of reprisals.
Supplier Due Diligence
Due to recent acquisitions, the Company is now in a transition period in which the existing supply chain is being reviewed. This process will determine the business needs whilst helping to establish and assess areas of potential risk within the supply chain.
The Procurement Policy is also under review to ensure that all suppliers, contractors and business partners are required to demonstrate that they, and any organisations within their own supply chains, comply with the provisions of the Modern Slavery Act and follow the Company’s stance on preventing modern slavery and human trafficking.
In line with the Procurement Policy, the Procurement processes and procedures will include criteria which will govern how suppliers engage with the Company. All suppliers are expected to comply with, all relevant laws and regulations, the Company’s business policies and values. Audit expectations will be detailed in the commercial agreement / contracts. The frequency of audits will be evaluated by reference to the strategic nature of the supplier, the value of spend and according to the goods or services being supplied. The Company has in place, systems to highlight any potential risk in regard to sourcing and supplying goods and/or services.
Key performance indicators (KPIs) are used to measure how effective the Procurement processes have been to ensure that slavery and human trafficking is not taking place in any part of the Company or its key supply chain.
The Company is currently focusing on raising internal awareness, to including via communications and internal bulletins to enable our key staff to understand the requirements of the Modern Slavery Act and enable them to identify potential issues. New training which will be available to all staff, with tailored training for those involved in recruiting and sourcing/managing a supply chain so that they are able to identify risk factors, understand the implications and assist with implementing the Anti-Slavery Policy effectively.
The Procurement function is to be enhanced. This will drive a new way of managing the supply chain and working through processes, procedures and active governance through the introduction of specific measures to support the Company’s obligations under the Act.
This statement has been approved by the Members who will review and update it annually.