Modern Slavery Act 2015

Slavery and Human Trafficking Statement

For the financial year ending 30 April 2022

Introduction 

Stephenson Harwood LLP, a limited liability partnership law firm registered in England and Wales and authorised by the Solicitors Regulation Authority, is required to make this statement pursuant to section 54(1) of the Modern Slavery Act 2015. The statement relates to Stephenson Harwood LLP and all of its international offices ("the Stephenson Harwood Group" and "the Firm").

Over the course of the past year, we have implemented a number of measures and initiatives that directly and indirectly seek to mitigate the risk of modern slavery and human trafficking at the Firm and in its supply chain. This reflects our strong commitment to legal and regulatory compliance and ethical business conduct.

Structure of the Stephenson Harwood Group and internal and external responsibilities

Stephenson Harwood is a law firm with over 1100 people worldwide, including over 180 partners, that supplies legal services internationally through offices forming part of the Stephenson Harwood Group. Details of the Firm’s international offices can be found on the Firm's website (https://www.shlegal.com/legal-notices).

Stephenson Harwood LLP is registered in England and Wales and is headquartered in the London office. The Firm is regulated in England and Wales by the Solicitors Regulation Authority ("SRA").

The Firm's Risk Management department has primary responsibility for overseeing legal and regulatory compliance, including MSA compliance. The department is headed by Yamini Paramesan (Head of Legal and Regulatory Risk) who reports directly to the Firm's General Counsel, Gaby Kaiser. Over the last two years, the Risk Management department has significantly expanded, adding 5 full-time employees. This has allowed the department more effectively to monitor the Firm's legal and regulatory compliance and more thoroughly to investigate and enhance specific areas of compliance, including modern slavery and human trafficking.

As an SRA-regulated entity, the Firm has a Compliance Officer for Legal Practice ("COLP"), currently Paul Thwaite, a partner of Stephenson Harwood LLP. The COLP's responsibilities include ensuring that the Firm's partners and employees do not cause or substantially contribute to a breach of the Firm's regulatory arrangements. Staff are encouraged to report any suspicion or knowledge of modern slavery or human trafficking at the Firm or its supply chain to their line manager, the Risk Management department, the Firm's General Counsel and/or the COLP. Any such reports would be immediately investigated and, where appropriate, remediation action would be taken.

The firm also has a Whistleblowing policy to encourage reporting of any actual or perceived potential breaches (see more below). In order to facilitate such reporting from our partners, employees, agency workers and consultants, the Firm has established a whistleblowing hotline through an external service provider. The hotline is open 24 hours a day, 7 days a week.  All whistleblowing complaints are reported to the Head of Legal and Regulatory Risk and Human Resources for triage and, where appropriate, escalation and remediation.

Policies

Stephenson Harwood has a number of policies which address the risk of modern slavery and human trafficking at the Firm and in its supply chain.

Foremost among these is the Modern Slavery Act 2015 Policy ("the MSA Policy"). The MSA Policy sets out the Firm's commitment to transparency in its business and the high standard it sets for itself and its contractors, suppliers and business partners with respect to the need both to identify and tackle modern slavery. Pursuant to the MSA Policy, "the prevention, detection and reporting of modern slavery in any part of the Firm's business or supply chain is the responsibility of all those working for the Firm or under its control."

To facilitate this, the Firm's Whistleblowing Policy encourages all employees and partners to report any suspicion and/or knowledge of modern slavery and/or human trafficking by providing protection to employees making such reports. Furthermore, the Firm's Employee Handbook and Grievance Policy and Disciplinary Procedure serve to encourage ethical standards of conduct and to deter acts that violate internal rules such as the MSA Policy and external ones like the MSA itself. Lastly, the Firm's Risk Management Policy sets out the Firm's risk management team, which, as identified above, is responsible for monitoring and enforcing legal and regulatory compliance. This policy also sets out the risk-based approach to compliance that we apply to dealing with modern slavery and human trafficking risks.

Over the past year, the Risk Management department has reviewed and enhanced its platform on the Firm's Intranet with the aim of making it more accessible and user-friendly. This will allow partners and employees more easily to access the Firm's policies, including the aforementioned policies related to modern slavery and human trafficking, and related guidance. This platform will in future also be utilised for the publication of modern slavery and human trafficking-related initiatives.

The Firm is also subject to the SRA's Standard and Regulations which contain numerous relevant obligations. For example, the Firm:

• Must act in a way that encourages equality, diversity and inclusion (SRA Principle 6);
• Must identify, monitor and manage all material risks to its business (SRA Code of Conduct for Firms paragraph 2.5); and
• Cannot attempt to prevent anyone from providing information to the SRA or any other body exercising regulatory, supervisory, investigatory or prosecutory functions in the public interest (SRA Code of Conduct for Firms paragraph 3.11).

Risk assessment, due diligence and supply chains

Our assessment continues to be that the Firm and its supply chain pose a low risk with respect to modern slavery and human trafficking. To date, we are not aware of either having occurred within the Firm or in its supply chain.

Supplier Accreditation Questionnaire

This year, the Firm has built upon the use of its Supplier Accreditation Questionnaire and has developed a Supplier Accreditation Matrix. This is an invaluable tool for evaluating the suitability of potential suppliers with respect to their regulatory compliance and risk management.

Potential suppliers must complete the Supplier Accreditation Questionnaire which asks about their policies and procedures (including whether they have a Modern Slavery Act policy) and about whether they have various accreditations (including the Living Wage Accreditation). Based on their Questionnaire responses, potential suppliers receive scores which determine whether they are automatically accepted as a Firm supplier, or whether additional due diligence and/or management approval is necessary before they can become a Firm supplier.

Notably, potential suppliers who indicate on the Accreditation Questionnaire that they do not have a Modern Slavery Act policy cannot—regardless of all their other responses—receive automatic approval and will be contacted by the Firm in order to determine whether, from a risk perspective, they can serve as a supplier without such a policy.

Supplier Agreement Clauses

The Risk Management department is in the process of developing template modern slavery and human trafficking-related clauses for use in our supplier agreements. In the coming months, we will make these clauses available to our partners and employees on our intranet site and will launch a campaign to (1) raise awareness of these clauses among employees working in procurement and (2) educate these employees on the correct use of these clauses, such as when dealing with suppliers with a moderate-to-high risk of modern slavery and/or human trafficking.

Training

Over the last year, the Firm has expanded the scope and depth of its modern slavery-related training. All partners and employees, upon joining the Firm, are required to attend a live risk management induction training session, which includes in each of its iterations information concerning the Modern Slavery Act and how the legislation, and the principles underpinning it, are captured and complied with in the context of the Firm's procurement processes.

Additionally, we have added to our online training catalogue a course entitled "Modern Slavery Act: Preventing Exploitation". Completing this course is mandatory for (1) members of the Firm's Central Management Team; (2) the head of each business services department; and (3) employees with significant procurement-related responsibilities and supplier interaction. By adding this course and making it mandatory for the aforementioned groups of people, those at the Firm most exposed to modern slavery risks and those best situated to take action to mitigate these risks will benefit from an in-depth understanding of modern slavery and how to combat it.

KPIs

ESG Score

The Firm continues to work with an external ESG auditor, who undertakes an annual audit of our ESG approach — including how we respond to modern slavery risks in our supply chain — and provides us with an ESG rating which we seek to improve year on year.

Mandatory Training Compliance

For our rollout of the "Modern Slavery Act: Preventing Exploitation" course, we are aiming for a completion rate of at least 90% of those to whom the course was assigned as mandatory training.

Employee Wages

In the UK, Stephenson Harwood is an accredited Living Wage employer and pays all employees above the current Real Living Wage. Where our overseas offices are in a jurisdiction with a statutory minimum wage, we pay above that minimum wage. In Dubai, where there is no such minimum wage and where we have an office, we benchmark every job role against the market to make sure that everyone is paid fairly.

Other

Pro bono services

The Firm continues to provide pro bono services to groups of individuals that are vulnerable to being exploited with respect to their working conditions and remuneration, including domestic workers in Hong Kong and victims of wage theft in the UK. In the last year, we entered into a new partnership with Breaking Barriers, a UK charity that helps refugees rebuild their lives through education, training and employment.

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Designated Member - Eifion Morris



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Designated Member - Roland Foord

For and on behalf of Stephenson Harwood LLP

Date: 27 October 2022