Modern Slavery and Human Trafficking Statement
20 April 2018
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, which is incorporated in England & Wales (Reg. No. 303620) (Reed Smith). Reed Smith is associated with Reed Smith LLP of Delaware, USA.
Recorded in the Statement are the actions taken by Reed Smith during 2017 to ensure that modern slavery and/or human trafficking does not take place within its supply chain or is in anyway associated with its business.
This Statement was approved by Tamara Box, EME Managing Partner and Designated Member of Reed Smith on 20 April 2018.
Our goal is always to be “Doing The Right Thing.” We work to the highest professional standards. Our commitment to our goal of always to be “Doing the Right Thing” 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 LLP of Delaware provide legal services and operate through offices in Abu Dhabi, China, Dubai, France, Germany, Greece, Hong Kong, Kazakhstan, Singapore, UK and the United States.
We remain committed to work toward 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.
Although we regard the provision of legal advice as a business with a low risk of having involvement with human trafficking and slavery, we are not complacent. We are aware of the scale of the problem and the efforts of the 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 is free from modern slavery.
Action taken in 2017
We have built on the work done in 2016. The cross-functional working group, which was formed in December 2015, continues to meet and has been increased in size to include a representative from the U.S. business.
The work undertaken in 2016 involved the UK business undertaking a review of its supply chain to assess the risk of any supplier having an involvement with modern slavery. The result of that exercise was that 57 suppliers were assessed as medium risk. Further due diligence has been obtained on all of the suppliers that were assessed as medium risk to ensure that the supplier has a commitment to the elimination of modern slavery. The due diligence exercise included a review of each supplier’s website to identify evidence of a commitment to elimination of modern slavery. Suppliers that do not display a Modern Slavery Act policy on their website have been contacted and required to confirm their commitment to comply with our Modern Slavery and Human Trafficking Policy (our Policy).
Reed Smith imposed a requirement that from 1 January 2017 any new arrangement with a supplier includes a commitment to comply with our Policy. During 2017 it was identified that this requirement to put in a place a contractual commitment with some low-value and low-risk suppliers, by way of example, those providing our library service with access to electronic databases, was causing a disproportionate administrative burden. As a result, the requirement has been amended for low-risk suppliers where we have an annual spend of less than £5,000, such that contact with the supplier on this issue is now limited to informing the supplier that they are required to comply with our Policy.
Reed Smith is working to identify charities or not-for-profits that Reed Smith can work with and that have a focus on the elimination of modern slavery and human trafficking, in areas where Reed Smith has offices.
It is the intention of Reed Smith to put in place in 2018 a more systematic and automated approach to checking that its suppliers are committed to working toward the elimination of modern slavery and human trafficking.
Recorded in the 2017 Statement was the intention of the U.S. business, from early in 2017, to require any new arrangement with a supplier to include a commitment by the supplier to comply with the Policy. A system has been established by the Reed Smith U.S. business to ensure that all new relevant suppliers (we have excluded entities such as courts and other similar entities to whom payments are made) are contacted and informed of our requirement that the supplier complies with our Policy.
The focus in 2017 was on raising general awareness throughout Reed Smith of the obligations contained in the Act and the presence of modern slavery and human trafficking throughout the world.
In relation to the UK business, we have continued to mention our initiatives concerning modern slavery when those working at Reed Smith are gathered to attend presentations.
In the United States, in June 2017, training was provided to all U.S.– based Business Managers and Operations Directors with responsibility for the procurement process in relation to our Policy and initiatives. To increase awareness of our U.S.-based lawyers, mention is made of our Policy and initiatives at presentations given on risk management and compliance topics.
Other Reed Smith human rights initiatives
Reed Smith is committed to upholding and promoting human rights through the manner in which it conducts its business. This includes its pro bono programs where one of the main focuses is supporting international human rights projects. This work includes working with Lawyers Without Borders and Liberty Asia to combat human trafficking, assisting Amicus and Reprieve on death penalty casework, partnering with The Human Dignity Trust to protect LGBTI rights, and working with a number of organizations to eradicate female genital mutilation, as well as extensive work around the world to protect refugees.
Tamara Box Date 20 April 2018
Designated Member Reed Smith LLPEME Managing Partner
View a copy of the 2017 statement