Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015 (“the Act”). We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
This policy aims to prevent slavery and human trafficking within the firm’s business and supply chains. It should also be considered alongside the firm’s Professional Conduct and Business Ethics Polices and the London Offices’ Outsourcing Policy.
The Modern Slavery Act came into force on 29 October 2015. It created additional criminal offences for those committing such acts, and had the intention of seeking to establish transparency in supply chains in modern commercial organisations.
Section 54 of the Act provides that a commercial organisation which supplies goods or services and has a prescribed turnover (currently set at £36 million) shall establish a policy on how to combat modern slavery.
The Solicitors Regulation Authority (“the SRA”) also places a burden on us to comply with the requirements of the Act. The SRA requires all law firms to ‘uphold the rule of law and proper administration of justice’ and ‘to act with integrity’. All solicitors and employees are required to ensure that they ‘do not discriminate unlawfully, or victimise or harass anyone, in the course of your professional dealings’.
In accordance with section 54 (1) of the Act, the firm will prepare a slavery and human trafficking statement for each financial year. The statement will:
Further, the firm will take all reasonable steps to ensure that its current suppliers have, and will do so on an annual basis confirm that they have robust oversight of their operations and processes, and can with sufficient confidence confirm that there are no risk of incidents of modern slavery or human trafficking. The firm will ensure that all new suppliers provide similar declarations as to current suppliers, before commencing any provision of services to the firm.
The firm may terminate the business relationship with any supplier which fails to provide an appropriate declaration or assurances that it has satisfactorily assessed its own risk of involvement in Modern Slavery.
The following policy applies to all persons working for Morgan Lewis & Bockius UK LLP (“the Firm”) or on our behalf in any capacity, including Partners, employees, agency workers, secondees, volunteers, interns, contractors, external consultants, third-party representatives and business partners.
This policy does not form part of any employee's contract of employment and we may amend it at any time.
Frances Murphy, Office Managing Partner, and Nick Greenwood, Compliance Officer for Legal Practice, have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Head of Risk & Compliance, London has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Head of Risk & Compliance, London.
Training on this policy, and on the risks our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Anyone who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.