Modern Slavery Act 2015: Modern Slavery and Human Trafficking Statement
This Modern Slavery and Human Trafficking Statement is made by Bird & Bird LLP (the "firm" or "we") under section 54(1) of the Modern Slavery Act 2015 (the "Act") for financial year ended 30 April 2019 and was approved and signed on behalf of the Board of Bird & Bird LLP on 17 September 2020.
The Firm
Bird & Bird LLP is committed to legal compliance and ethical business practices in all of our operations worldwide, this includes improving our practices to combat slavery and human trafficking. We choose suppliers and contractors who we believe share that commitment.
Risk Assessment
As a professional services firm regulated in the various jurisdictions in which we operate, and having adopted a globally applicable Ethics Policy in January 2013 (reviewed and restated in 2019), we consider that that we are at low risk of modern slavery occurring within our own business. However we remain alert to the possibility, and our policy and reporting requirements cover our approach to this. There is a greater risk in our supply chain which comprises non-regulated businesses.
Our key suppliers are those required to support our global professional service business, which is office based. The key areas of spend with suppliers are IT and Facilities Management (including catering and cleaning), with additional spend on recruitment, training & education and marketing. Global spend on suppliers is concentrated in London, with other spend distributed across other international offices. Our aim is to foster long term relationships with our critical business suppliers, as this is key to establishing an open relationship where price is not the only driver.
Policy on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery and Human Trafficking Policy reflects our commitment to use only legal and ethical business practices and to implement and enforce effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we have procured training resources for staff with direct contact and responsibility for procurement within the firm, and the training is required for those with direct procurement responsibilities.
Accountability
We require all members, partners, employees, officers, directors and consultants of the firm, including temporary workers and others who are subject to the direction of the firm, to comply with our Anti-slavery and Human Trafficking Policy. As with all alleged violations of policy, we investigate issues and take the appropriate action up to and including termination of employment and termination of agreements for suppliers and contractors.
Progress
Bird & Bird has implemented third party supplier management tool to allow consistent due diligence on critical suppliers across a range of issues including Modern Slavery compliance. Use of the system is based on a risk analysis by sector and spend. Non conformities are flagged and followed up by the relevant budget holder.
Relevant departments are required to make sure the right people undertake our anti-modern slavery training, including relevant new joiners.
All London based suppliers pay their staff the London Living Wage, with other offices being encouraged to seek out similar schemes.
We continue to improve procurement processes in London with greater oversight of spending, allowing more scrutiny of potentially higher risk suppliers.
Resources and knowledge are being shared across other offices to improve awareness and improve practice.
An assessment of Modern Slavery compliance and awareness will be part of the next phase of our firm wide internal audit process, Operational Review.
Next steps
We will:
- Continue to review our approach to Modern Slavery to evaluate its effectiveness and identify any gaps.
- Make further improvements to our supplier screening process and risk based assessment of suppliers.
- Expand and embed knowledge of the issues and risks around modern slavery and human trafficking to all appropriate staff across the network of offices via regular communication and targeted training.
- Incorporate assessment of modern slavery awareness and compliance in our ongoing operational risk review process across our network of offices. The outcomes of the Operational Review process will be reviewed at Board committee level to identify gaps in knowledge and where practice can be improved.
Signature:
David Kerr
Chief Executive Officer
On behalf of the Board
Bird & Bird LLP
Date: 8 October2020