Date 21 April 2020
Purpose of this statement
This statement (the Statement) is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the Act) on behalf of Reed Smith LLP (Reed Smith), which is incorporated in England and Wales (Reg. No. 303620). Reed Smith is associated with Reed Smith LLP of Delaware, USA (Reed Smith U.S.).
Recorded in the Statement are the actions taken by Reed Smith during 2019 to ensure that modern slavery and human trafficking does not take place within its supply chain and is not in any way associated with its business.
Tamara Box, Europe & Middle East (EME) managing partner and designated member of Reed Smith, approved this Statement on 21 April 2020.
Our goal is always to be ‘doing the right thing’, and to work to the highest professional standards. Our commitment to these goals is reflected in how we run our firm. Through our Responsible Business program, we play an active part in the community, supporting others and bringing about beneficial change wherever we can.
Reed Smith and Reed Smith U.S. provide legal services and operate through offices in Belgium, China, France, Germany, Greece, Hong Kong, Kazakhstan, Singapore, UAE, UK, and the United States.
We are committed to working towards the elimination of any possibility of slavery in our supply chain. Reed Smith’s supply chain is similar to the supply chain of other professional service businesses and is relatively simple. The key services we procure are property space, facilities management, professional services, and information technology. The sourcing and purchasing of goods and services is supported across the firm by our global procurement team based in Pittsburgh.
Although we regard the provision of legal advice as a business with a low risk of involvement with human trafficking and slavery, we are not complacent. We consider that in some of our practice areas, there are known concerns as to human trafficking and slavery, for example, our transportation practice and our energy and natural resources (ENR) practice.
During 2019, the firm’s cross-functional modern slavery working group reviewed the firm’s practice areas and concluded that our general assessment of risk in relation to human trafficking and slavery occurring in our supply chain is low. We are aware of the scale of the problem and the efforts of authorities in many countries who struggle to deal effectively with these serious crimes. We continue to monitor and work to improve the systems in place to ensure that our business and supply chain are free from modern slavery.
Action taken in 2019
We have built on the work performed in prior years.
The cross-functional working group, formed in December 2015, continues to meet and was strengthened by representatives joining from our UAE office and our transportation and global commercial disputes (GCD) practice groups.
During 2019, the group worked to increase awareness of modern slavery issues within Reed Smith, specifically in higher risk areas such as our transportation and ENR groups. Our global procurement team also continued to raise awareness of modern slavery and human trafficking issues with our suppliers.
Suppliers: risk assessment process
Since 1 January 2017, there has been included in any new arrangement with a supplier a commitment by the supplier to comply with our Modern Slavery and Human Trafficking Policy (Policy).
In 2019, we decided to repeat a review of all of Reed Smith’s suppliers using a risk-based approach, previously undertaken in 2016. The assessment involves consideration of a number of factors which are broadly (1) location where the service or goods are supplied, (2) the industry sector from which the services or goods are provided, and (3) the labour practices specific to the industry and the location from which the particular services or goods are supplied. The assessment started in the final quarter of 2019 and will conclude in 2020.
Suppliers: U.S. business
From early 2018, all new arrangements with suppliers have included a commitment by the supplier to comply with our Policy. We consider any person or organization to whom payment is made by Reed Smith U.S. to be a supplier. Reed Smith U.S. has established a system that ensures all new suppliers (excepting entities such as courts and notaries) are contacted and informed of the requirement that they comply with the Policy. As part of this process, a declaration is required from the supplier to confirm compliance with the Policy. In June 2019, an additional declaration was added, requiring the suppliers to certify that they have a program in place to ensure that human trafficking and modern slavery does not exist within their operation and supply chain and that they require compliance from their suppliers. If the supplier certifies that it has such a policy in place, we request a copy of their policy.
Reed Smith U.S. has developed a SmartSurvey which is being sent (in phases) to every supplier who has been paid by the firm one or more payments of $1,000 or more within the last two years. The survey includes our Policy and requires the supplier to record whether they comply with our Policy. Should the supplier inform us that they do not comply, we contact the supplier to find out why they have recorded that they do not comply.
Suppliers: firmwide suppliers
A contract management process has been developed for use with all suppliers which will be rolled out in 2020. This process requires that all new, potential suppliers provide evidence of their modern slavery and human trafficking policies.
Training and awareness
In 2019, the cross-functional working group continued to focus on raising awareness throughout the firm, specifically to inform individuals of the obligations contained in the Act and the presence of modern slavery and human trafficking throughout the world.
There continues to be mention, from time to time, of our initiatives concerning modern slavery when those working at Reed Smith gather to attend internal meetings. Further, our online modern slavery and human trafficking eLearning has been specifically communicated to our higher risk practice areas (Transportation and ENR). This eLearning is also available to all employees of Reed Smith, on the firm’s Learning and Development page.
In 2020, we will be reviewing our staff profile to determine groups within the firm who will be required to undertake this learning as a mandatory requirement, on an annual basis. This will include managers and employees working in procurement roles and those who have direct responsibility for the arrangement and management of contracts entered into with suppliers.
Other Reed Smith human rights initiatives
Reed Smith is committed to upholding and promoting human rights through the manner in which it conducts business. This includes its pro bono programs where one of the main focuses is supporting international human rights projects, including:
- Lawyers Without Borders – working on a long-term project to combat human trafficking in the commercial supply chain, including the production of education materials to be used in Tanzania to help to fight human trafficking.
- Liberty Asia – our Hong Kong and Singapore offices work with Liberty Asia to assist this organisation to end modern slavery in Asia by providing legal advice on areas relating to modern slavery and human trafficking.
In the financial year ending 31 December 2020, we aim to:
- Continue to assess and monitor the risks and raise awareness of human trafficking and slavery risks in our supply chain through our due diligence exercises and management of the activities of all our suppliers.
- Further increase awareness within Reed Smith through training on modern slavery and human trafficking and providing firmwide updates.
- Continue our pro bono work to support international human rights projects.
- Redefine our modern slavery and human trafficking strategy, as and when proposed reforms to the legislative regime are implemented.
Tamara Box Date 21 April 2020
Designated member Reed Smith LLP
EME managing partner