Date April 21, 2022
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 2021 to ensure that modern slavery and human trafficking do 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, 2022.
Our goals are to always 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 proposed an amendment to the Act in 2020 to require that any statement, produced pursuant to the Act, must include information on six areas. In anticipation of that proposed change, we set out in the Statement our response to each of the six proposed mandatory 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 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 involves the consideration of a number of factors which are broadly (1) the location from which 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. The assessment started in the final quarter of 2019, and was originally expected to conclude in 2020. However, due to the continuing impact of the COVID-19 pandemic the review has not been concluded.
During 2021 a risk assessment of the suppliers to Reed Smith’s UK offices was carried out and the modern slavery policies of those suppliers were collected. Suppliers whose policies were not available on their websites were contacted in order to obtain copies of their policies.
The review of the suppliers to our UK offices should conclude in early 2022. On completion of that exercise a review will be undertaken of suppliers to Reed Smith’s offices outside of the UK.
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 (except 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 has been delayed 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 regarding human trafficking and slavery, for example, in our transportation practice and our energy and natural resources practice. For these higher risk areas, we have supplied training to those groups, and representatives from those practice areas are also part of our cross-functional modern slavery working group.
(5) Our effectiveness, measured against performance indicators that we consider appropriate
During 2021, 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.
UK Government guidance is that the effectiveness of measures taken by an organisation to ensure that slavery and human trafficking is not taking place in its supply chain or business should be measured against key performance indicators. The Reed Smith modern slavery working group will review the following key performance indicators:
- The number of slavery suspicions reported through the Modern Slavery Policy;
- Employees e-learning statistics;
- Responses from our suppliers during the due diligence processes.
Other Reed Smith human rights initiatives undertaken in 2021
Reed Smith is committed to upholding and promoting human rights through the manner in which it conducts business. This includes our pro bono programs, where one of the main focuses is supporting international human rights projects, including:
- Lawyers Without Borders
Lawyers Without Borders is an international not-for-profit organization that develops programs and materials to improve access to justice. Amongst other things, Lawyers Without Borders works to combat the heinous crime of human trafficking in developing countries through capacity-building training and the development of training materials.
More than 30 of our lawyers across six EMEA offices contributed to the production of a “Community Outreach Manual.” This innovative, practical guide will be used directly on the ground in Tanzania by Lawyers Without Borders’ local partners (national and international non-governmental organisations) to facilitate critical community dialogue that embraces Tanzania’s unique cultural norms. Its aim is to empower Tanzania’s communities to identify, prevent and report the crime of human trafficking through a ‘whole of community’ dialogue.
A team of around 40 Reed Smith lawyers across nine EMEA offices have produced essential guidance for trainers (including prosecutors, judges, police officers, labour inspectors and lawyers) on the crimes of human trafficking, child labour, and forced labour in Thailand. The manual provides trainers with a detailed overview of the crimes’ underlying causes and trends and their impact on society, along with a full appraisal of relevant domestic and international legislation. This guidance will assist with enforcing human trafficking, child labor, and forced labor offences in Thailand to protect and secure justice for victims.
- Liberty Shared
Our Hong Kong and Singapore offices work with Liberty Shared to assist the organization in its mission to end modern slavery in Asia by providing legal advice in relation to modern slavery and human trafficking.
We are exploring the possibility of providing pro bono support to a number of other modern slavery and human trafficking charities.
(6) Training and capacity building available to our staff
In 2021, 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 is available to all employees of Reed Smith on the firm’s Learning and Development page.
A new modern slavery eLearning package will be rolled out to employees in early 2022.
In the financial year ending December 31, 2022, we aim to:
- Continue to assess the modern slavery and human trafficking risk in our supply chain from our existing and new suppliers.
- Provide training on modern slavery and human trafficking throughout Reed Smith and continue to raise general awareness of these topics.
- Continue our pro bono work to support international human rights projects.
Tamara Box Date April 21, 2022
Designated member of Reed Smith LLP
EME managing partner