Date April 21, 2021
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 2020 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 April 21, 2021.
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.
The UK government has proposed an amendment to the Act to require that the Statement, produced pursuant to the Act, must include information on six areas. In anticipation of that proposed change, we have set out in this Statement our response to each of the proposed mandatory six areas.
(1) Our structure, business, and supply chains
Reed Smith and Reed Smith U.S. provide legal services and operate through offices, and associated law firms, in Belgium, China, France, Germany, Greece, Hong Kong, Kazakhstan, Singapore, UAE, UK, and the United States. More information regarding our structure can be found at reedsmith.com.
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 are supported across the firm by our global procurement team based in Pittsburgh.
(2) Our policies
We have a Modern Slavery and Human Trafficking Policy (Policy). In addition, we have various other policies available to all staff through the Reed Smith intranet, which provide information regarding the behavior we expect of our personnel. These policies include our Code of Conduct, Risk and Ethics policy, and our Whistleblowing policy.
(3) Our due diligence procedures
Since January 1, 2017, there has been included in any new arrangement with a supplier a commitment by the supplier to comply with our 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 involved 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 labor practices specific to the industry and the location from which the particular services or goods are supplied. This assessment started in the final quarter of 2019, and was to conclude in 2020. However, due to the impact of the COVID-19 pandemic, we were unable to complete this review in 2020, especially given that some of our suppliers were severely impacted by the COVID-19 pandemic. We now hope to complete this review in 2021, once the impact COVID-19 pandemic has subsided.
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 that they are required to 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 that is 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. This was originally planned to be rolled out in 2020, but this was delayed until 2021 due to the COVID-19 pandemic. This process will require that all new, potential suppliers provide evidence of their modern slavery and human trafficking policies.
(4) Risks of slavery or human trafficking in relation to our supply chain and business
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, in our transportation practice and our energy and natural resources (ENR) practice. For these higher risk areas, we have supplied training to those groups, and representatives from those practice areas also sit on our cross-functional modern slavery working group.
(5) Our effectiveness, measured against performance indicators that we consider appropriate
During 2020, the firm’s cross-functional modern slavery working group continued to meet on a quarterly basis to discuss the firm’s modern slavery initiatives and level of risk in this area. Generally, the group assessed the risk in relation to human trafficking and slavery occurring in our supply chain as low. We are aware of the scale of the problem and the efforts of authorities in many countries that 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.
To date we have not identified key performance indicators (KPIs) that we can use to report progress. However, in this Statement, we have included information regarding our efforts to eliminate modern slavery and human trafficking from our supply chains during 2020 and reported against our proposed actions that were contained in our previous modern slavery statement for 2019. In 2021, the cross-functional modern slavery working group will continue to review the possibility of developing KPIs for use in future reporting.
Other Reed Smith human rights initiatives undertaken in 2020
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 – we work to combat human trafficking with Lawyers Without Borders. In 2020, we prepared a manual to facilitate and foster a dialogue about human trafficking in local communities. This manual will be used directly on the ground in Tanzania by Lawyers Without Borders’ local partners (national and international non-governmental organizations).
- Liberty Shared – our Hong Kong and Singapore offices work with Liberty Shared to assist this organization to end modern slavery in Asia by providing legal advice in areas relating to modern slavery and human trafficking. Last year, a team from our Hong Kong office took on a human trafficking case for an individual.
- Exploring partnerships with a number of other modern slavery and human trafficking charities we hope to provide pro bono support to in 2021.
(6) Training and capacity building available to our staff
In 2020, the cross-functional working group continued to focus on raising awareness throughout Reed Smith, and, in particular, 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, we have an online modern slavery and human trafficking eLearning course that has been made available to our higher-risk practice areas, notably, our Transportation and ENR groups. This eLearning is also available to all employees of Reed Smith on the firm’s Learning and Development page.
We have also delivered virtual modern slavery training to our personnel based in London and Leeds. This training was attended by 101 members of staff from those offices.
In 2021, we will further review our staff profile to determine groups within the firm that will be required to undertake modern slavery learning as a mandatory requirement.
In the financial year ending December 31, 2021, we aim to:
- Reassess the modern slavery and human trafficking risk in our supply chain by re-performing our risk assessment processes with our firm’s suppliers.
- Develop a training program for applicable staff on modern slavery and human trafficking and continue to raise general awareness of these topics throughout the firm.
- Continue our pro bono work to support international human rights projects.
Tamara Box Date April 21, 2021
Designated member Reed Smith LLP
EME managing partner