Modern Slavery and Human Trafficking Statement
20 April 2017
Our goal is always to be “Doing The Right Thing”. We work to the highest professional standards.
Our commitment to responsible business is reflected in how we run our firm. Through our Responsible Business programme, we play a part in the community, supporting others and bringing about beneficial change wherever we can.
We are committed to implementing and enforcing our Modern Slavery and Human Trafficking Policy. We both monitor and work to improve the systems we have put in place to ensure that modern slavery does not take place anywhere in our business and no one with whom we do business benefits from or in any way contributes to Modern Slavery.
It is the responsibility of all at Reed Smith to ensure compliance with our Policy. We work to ensure that all who work at Reed Smith fully understand how we strive to improve the impact of our Policy. We have in place mechanisms to deal with any concerns or breaches of the Policy including arrangements for reports to be made anonymously by telephone or over the web, details of which are contained in our Policy. Confidentiality will be protected to the fullest extent possible.
We expect all who do business with us, including those in our supply chain, to have the same commitment, as we do, to our Policy.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (“the Act”) on behalf of Reed Smith LLP, which is incorporated in England & Wales (Reg. No 303620). Reed Smith LLP is associated with Reed Smith LLP of Delaware, USA.
Reed Smith LLP is a firm which provides legal services, that operates in Abu Dhabi, China, Dubai, England & Wales, France, Germany, Greece, Kazakhstan, and Singapore, either directly or through an entity it controls.
Given that our business is the provision of professional services, we consider that the risk of Modern Slavery within our business or our supply chain to be low, but we are conscious that Modern Slavery occurs in different forms throughout the world, including in the UK.
In December 2015 we formed a cross- functional working group to consider what actions we would take to ensure compliance with the Act. The primary focus of the group is the business which is managed from the London office. It is intended that the group will progressively build, each year, on the work which has been done in prior years.
One of the first tasks undertaken by the working group was to assist with the drafting of the Policy. This sets out our zero-tolerance to Modern Slavery and identifies how any concerns can be reported. The Policy was adopted in October 2016. All who work for Reed Smith LLP were informed of its adoption and were sent a link to the Policy.
Supply chain - UK business
We have developed a risk- based approach to the assessment of the possibility that Modern Slavery exists within Reed Smith LLP’s supply chain. Those undertaking the assessment have reviewed all suppliers. For each supplier information has been collected as to the identity of the actual supplier, the services or goods provided to Reed Smith LLP’s business, and the contract value. When undertaking the assessment a number of factors were then considered which are broadly (1) location where the service or goods are supplied, (2) the industry sector from which the services or goods is provided, and (3) the labour practices specific to the industry and the location from which the particular services or goods are supplied. Labour practices reviewed included consideration of issues relating to recruitment (e.g. whether workers were charged excessive recruitment fees or fraudulently charged for health checks), during employment( e.g. underpayment or withholding passports), and termination (e.g. worker’s visa tied to employer or a requirement on the worker to pay a deposit by way of runaway insurance). The result of the exercise was that, out of approximately 1,300 suppliers none were assessed as high risk, 57 were assessed as medium risk and the rest as low.
Those suppliers who have been assessed as medium risk will be subject to enhanced due diligence. Consideration will be given, as part of the further due diligence exercise to be undertaken, on the suppliers assessed as medium risk as to whether any requirements should be imposed on any supplier in order to ensure compliance with the Policy.
From 1 January 2017 any new arrangement with a supplier will included a commitment by the supplier to comply with the Policy.
Supply chain - US business
Reed Smith LLP is supplied with services and goods via its associated US law firm. The US firm intends, from early 2017, to require all new suppliers to complete a form which will include a notice that informs the supplier that it is required to comply with Reed Smith LLP’s Policy and that failure to comply with the Policy may result in the contract being terminated.
Our focus has been on raising awareness as to the obligations contained in the Act and the presence of slavery and human trafficking throughout the world. Information regarding what Modern Slavery is and how it may impact our business was sent to all who work for Reed Smith LLP when the Policy was launched, as well as having been publicised in a blog of the firm’s intranet.
Information about the Policy has also been provided to approximately 65% of those who work in the London office in conjunction with other live training.
Tamara Box Date 20 April 2017
Designated Member Reed Smith LLP
EME Managing Partner