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Modern Slavery Act 2015

Slavery and Human Trafficking Statement

For the financial year ending 30 April 2021

Introduction 

Stephenson Harwood LLP ("the Firm") meets the criteria of section 54 of the Modern Slavery Act 2015 ("MSA") and is therefore required to publish an annual slavery and human trafficking statement. This statement relates to Stephenson Harwood LLP and all of its international offices ("the Stephenson Harwood Group").

In addition to complying with its regulatory obligations, the Stephenson Harwood Group is committed to the highest ethical and professional standards when providing legal services to its diverse client base. This includes a zero-tolerance approach to modern slavery and human trafficking within the firm and in its supply chain.

Structure of the Stephenson Harwood Group and internal and external responsibilities

Stephenson Harwood is a law firm with over 1100 people worldwide, including 187 partners, and 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 London office. The firm is regulated in the United Kingdom 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 Risk Management department is headed by Yamini Paramesan (Head of Legal and Regulatory Risk) who reports directly to the firm's General Counsel.  As an SRA-regulated firm, Stephenson Harwood 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 the breach of the Firm's regulatory arrangements.  Firm 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 taken. In addition, the firm has a Whistleblowing policy to encourage reporting of any actual or perceived potential breaches (see more below).

Policies

The Firm has implemented a number of policies which address the risk of modern slavery and human trafficking at the Firm and/or in its supply chain.

The most directly relevant is the Modern Slavery Act 2015 Policy. This 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. The policy expressly states that "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 help make this possible, 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. In addition, 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 structure, 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.

The Firm is 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

We have determined that the Firm and its supply chain pose a low risk for modern slavery and human trafficking and, to date, there has not been an identified instance of either at the Firm and/or in its supply chain.

The Firm's current procurement process includes the use of a Supplier Accreditation Questionnaire which suppliers are asked to complete as part of our due diligence process. The questionnaire includes questions regarding the MSA, namely whether the supplier is subject to the MSA's transparency obligations and whether the supplier has a policy in place with regard to the MSA or other equivalent policy to ensure there is no slavery or human trafficking within their business or supply chain.

Moreover, to better ensure that we are monitoring potential modern slavery and human trafficking issues, we are developing a more formal risk assessment procedure for the Firm's suppliers that will focus primarily on jurisdiction and supplier type. Suppliers found to be high risk for modern slavery and human trafficking will be subject to more rigorous due diligence and may be required to include modern slavery-related contract terms in the relevant procurement contract.

KPIs

The Stephenson Harwood Group has recently launched a significant ESG initiative through which we are developing a wide-ranging ESG strategy for the Firm, and have set up an ESG Hub to provide our clients with ESG assistance and expertise. One of the initiative's key workstreams—Governance and commercial behaviours—is concerned among other things with identifying and addressing modern slavery and human trafficking risks. As a part of this initiative, the Firm has retained an external auditor to undertake an assessment of the Firm's ESG approach and provide us with an ESG rating, which will be based in part on how we seek to address modern slavery in the Firm's supply chain.

Starting in 2022, the Firm will be making training on MSA compliance mandatory for a select group of employees (see following section) and we will be tracking as a KPI what percentage of the employees in this group have completed the training within the requested timeframe. We are aiming for a completion rate of 90% but will revisit this target at the end of 2022.

Training

We provide ethics and legal and regulatory compliance training to our employees through a variety of mediums, including through in-person sessions, online courses and email communications.  This ensures that the Firm's training is as effective and has as wide a reach as possible.

The Firm's online training courses are provided by an external supplier and includes a course on MSA compliance. Completing this course will be mandatory for the heads of the Firm's business services departments and for those other employees who are responsible for overseeing the procurement of goods and services, both in London and internationally from 2022.

Since early 2021, the Risk Management department has been delivering ethics and regulatory compliance training to the Firm's business services employees. Starting in November 2021, the Risk Management department will also be providing induction training to all new business services employees upon their joining the firm. The training provided to new employees who are involved in procurement will include additional information on modern slavery and human trafficking risks at the firm and in its supply chain.

Other

The Firm works with reputable recruiters to meet its staffing needs and undertakes thorough background and identity checks on new employees. Employees working in the firm's London office are paid no less than the London Living Wage.

Lastly, as part of the Firm's commitment to being socially responsible corporate citizens, we work with various charities to provide assistance to highly vulnerable groups and to help prevent their members from falling victim to modern slavery and human trafficking. This includes:

  • Providing pro bono support to domestic workers in Hong Kong;
  • Supporting the Business Behind Refugees campaign which assists Afghan refugees with employment in the UK; and
  • Training lawyers to take on pro bono cases representing victims of wage theft as part of LawWorks' Unpaid Wage Project.

Designated Member
…………………………………………………………………………………….
Designated Member - Eifion Morris


Roland Foord's signature
…………………………………………………………………………………….
Designated Member - Roland Foord

For and on behalf of Stephenson Harwood LLP

Date: 29 October 2021

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© Stephenson Harwood LLP 2016. Any reference to Stephenson Harwood in this document means Stephenson Harwood LLP and/or its affiliated undertakings. Any reference to a partner is used to refer to a member of Stephenson Harwood LLP.