Modern slavery statement

This Statement is made pursuant to section 54 of the Modern Slavery Act 2015 (the Act) and sets out the steps Trowers & Hamlins LLP, its subsidiaries and affiliates (together referred to as the LLP) have taken to ensure that slavery and human trafficking is not taking place in our supply chain or in any other part of our business.

The LLP is committed to combatting modern slavery in all its forms. This is underpinned by our commitment to governance and accountability, as outlined in our updated responsible business report (Transitioning from strategy to reality - Responsible Business Report 2023) which forms a key part of the LLP's wider strategic objectives. This Statement highlights the key activities we have undertaken in pursuit of this objective during this financial year.

The Management Committee of the LLP approved this statement for and on behalf of the members of the LLP. This statement relates to the period to 30 April 2024.

The LLP is an international law firm headquartered in the UK, with offices in Manchester, Birmingham, London, Exeter, Abu Dhabi, Dubai, Bahrain, Oman, Malaysia and Singapore.
We work to the highest professional standards and comply with all laws, regulations and rules relevant to our business, and we expect the same from our suppliers and business partners. The LLP's supply chain includes the following industries:

• IT (hardware and software) and telecommunications;
• Facilities and office services (including cleaning, catering, security, facilities management and transport);
• Information services and knowledge management;
• Media, marketing, promotions and events;
• Employment, recruitment and employee benefits; and
• Finance and banking services . 

We are committed to acting professionally, fairly and with integrity and honesty in all of our business dealings and relationships wherever we operate. As a regulated professional services firm, we consider that that we are at low risk of modern slavery occurring within our own business. However, we remain vigilant to the possibility, and continually review our assessment. We have determined that, by nature, there is a greater risk in our supply chain (which comprises a broad range of suppliers) and therefore we take a risk-based approach to manage and mitigate those risks in the particular context of the relevant supply - as further detailed below.

We have a zero tolerance approach to modern slavery. Our Anti-slavery and Human Trafficking Policy reflects this commitment and details the systems and controls we have in place to prevent slavery and human trafficking. We continuously review and update our policies as required.

Regarding the prevention of modern slavery in our supply chain, over the course of the previous year we have undertaken the following activities:

• continued to follow our compliance procedures for onboarding new suppliers. This enables us to identify and assess potential risk areas in our supply chains;
• improved and mapped our process for onboarding new suppliers. Minimum standards have been documented, approved by the Management Committee and communicated to all stakeholders;
• updated our due diligence and risk assessment processes for onboarding new suppliers across our UK offices. We require new suppliers to complete our Anti-Bribery & Modern Slavery questionnaire (which has been updated). Further due diligence is undertaken on a risk-based basis depending on the responses to the questionnaire;
• added a new stage in our due diligence process for onboarding new suppliers to identify any potential sanctions concerns;
• continued to communicate the standards and behaviours we expect from our suppliers to them, and continued our current procedures for ongoing monitoring of suppliers;
• we are in the process of formalising these requirements in the form of a Supplier Code of Conduct and a Responsible Procurement Policy;
• continued to require our new and existing suppliers (upon renewal or evaluation of higher risk) where appropriate, to enter into contractual commitments to ensure compliance with the relevant rules and regulations, report instances of non-compliance and, where possible, a contractual right for us to exit triggered by any non-compliance;
• continued to implement our training programme for all new joiners and employees to raise awareness about modern slavery and the various forms it can take and what action to take if modern slavery or human trafficking is suspected in a supply chain; and
• continued to communicate our Whistleblowing Policy and the systems we have in place to protect whistle blowers.
  

We have intrinsic core values around equality, diversity and inclusion and responsible business. The firm has a variety of policies to foster a positive and fair working culture including our Responsible Business strategy and policies on: Equality, Diversity and Inclusion and Wellbeing and Stress Management.

We have Respect at Work and Whistleblowing Policies, alongside our culture of a non-discriminatory and open working environment which enables employees to report if they have concerns about any wrongdoing or breaches of the law or regulations. All concerns can be raised in confidence and without fear of disciplinary action.

We continually review our recruitment procedures and providers to ensure that all our employees are legally entitled to work in the jurisdiction which they are employed in.

We aim to ensure the wellbeing of all our employees by promoting mental and physical health through a variety of firm initiatives.

All employees in the UK are paid at least the minimum wage and in London employees and contractors whom we pay directly are paid the London Living Wage or above. For those suppliers where we are not in control of their wage structures, we ask them to provide confirmation that they are paying the London Living Wage (for services provided in London) or the minimum wage to those providing services outside of London.

Signed by Adrian Carter, Designated Member for and on behalf of Trowers & Hamlins LLP