Date 26 April 2019
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 2018 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.
Tamara Box, EME Managing Partner and Designated Member of Reed Smith, approved this Statement on 26 April 2019.
Our goal is always to be “Doing The Right Thing.” We work to the highest professional standards. Our commitment to this goal 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 are 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. The key categories 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 acknowledge that in some of our practice areas there are known concerns as to human trafficking and slavery, for example our shipping practice. However, 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 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 2018
We have built on the work performed in prior years.
The cross-functional working group, formed in December 2015, continues to meet and has been strengthened by representatives from the U.S. business Risk and Compliance and Knowledge Management joining the group.
During 2018, the main focus of the group has been to increase awareness of Reed Smith personnel and suppliers of the issues of slavery and human trafficking.
Suppliers: UK business
Since 1 January 2017 there has been included in any new arrangement with a supplier a commitment by the supplier to comply with our Policy.
In 2017, it was identified that this requirement to have in a place a contractual commitment with some low-value and low-risk suppliers, for example those providing our library service with access to electronic databases, was causing a disproportionate administrative burden. As a result, the requirement was amended for low-risk suppliers where we have an annual spend of less than £5,000 and those suppliers are now simply informed that they are required to comply with our Policy.
Suppliers: US business
From early 2018, all new arrangements with suppliers included a commitment by the supplier to comply with our Policy. We consider that any person or organization to whom payment is made by Reed Smith in the United States (Reed Smith U.S.) is a supplier. Reed Smith U.S. has established a system that ensures all new suppliers (we have excluded entities such as courts) are contacted and informed of our requirement that they comply with our Policy.
Existing suppliers are asked to confirm that they comply with our Policy. A process has been put in place to follow up with those suppliers who do not provide the requested confirmation, to determine the reason the confirmation has not been provided.
Suppliers: firmwide suppliers
We have developed a SmartSurvey to send out during 2019 to every supplier who has received one or more payments within the last two years. The Survey includes our Policy and requires a declaration to be returned to confirm compliance with our Policy. If the requested confirmation is not provided, contact will be made with the supplier to find out the reason.
Also, we intend in 2019 to ask suppliers who declared compliance with our Policy to provide evidence of work they have undertaken to comply with the Act.
Training and awareness
The focus in 2018 was on continuing to raise awareness, including throughout Reed Smith, of the obligations contained in the Act and the presence of modern slavery and human trafficking throughout the world.
We have continued to mention our initiatives concerning modern slavery when those working at Reed Smith are gathered to attend presentations. This has included mention in 12 live presentations provided in Nur-Sultan, Germany, Hong Kong, Middle East and the United States. Further training is planned for 2019, which has the aim of further increasing awareness throughout Reed Smith.
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 closely with Liberty Asia. Our Singapore office has been involved in the completion of “legal gaps analysis” in respect of laws on human trafficking that apply in Singapore.
In the financial year ending 31 December 2019, 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 the provision of training on modern slavery and human trafficking and the provision of firmwide updates.
- Continue our pro bono work to support international human rights projects.
Tamara Box Date 26 April 2019
Designated Member Reed Smith LLP
EME Managing Partner