Opening statement from senior management
Hill Dickinson LLP is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain, and imposes the same high standards on its suppliers, contractors and other business partners. Hill Dickinson LLP takes its responsibilities seriously and this statement constitutes its compliance pursuant to section 54 (1) of the Modern Slavery Act 2015 (the Act).
Structure of the organisation
Hill Dickinson LLP is a global law firm, established and operating as a limited liability partnership under English law. The HD group comprises a number of subsidiaries (where HDLLP is the parent company) and a number of separately constituted and regulated legal entities providing legal services in different jurisdictions. To find out more about the nature of our business, please go to www.hilldickinson.com.
In order to deliver its legal services, the firm works with a range of suppliers, the majority of whom are considered to be based in low risk jurisdictions.
Scope of the Modern Slavery Act 2015
The Act defines modern slavery as “slavery, servitude and forced or compulsory labour” and “human trafficking” (Modern Slavery). The Act requires commercial organisations operating in the UK (i.e. that supply goods or services from or to the UK) and have a global turnover above £36 million, to publish a statement each financial year, which sets out the steps they have taken to ensure there is no Modern Slavery in their business or supply chains.
As part of our commitment to combating Modern Slavery, we have launched a Modern Slavery policy in conjunction with this statement. This sets out our zero-tolerance approach to Modern Slavery in our organisation and supply chain, and highlights the steps that our staff can take if they are concerned about any such type of behaviour.
We have also taken steps to ensure that those of our suppliers (which we have identified as high risk) are aware of our policy, and adhere to the same high standards. It is our intention to extend this to all existing suppliers if and when their contracts with the firm come up for renewal and to all new suppliers in due course.
Our due diligence processes
As a professional services organisation, we consider the risk of Modern Slavery existing within our business to be low. However, we commenced our own due diligence programme in 2016, through a cross- functional working group, with a primary focus on operations managed from our UK Head Office. We intend to expand this due diligence to other jurisdictions in which we operate in due course.
Our supply chain
We endeavour to do business with suppliers that adopt the same strict standards that we ourselves adhere to. In turn, we expect our suppliers to operate fairly and ethically, where workers are treated with respect and dignity, and the highest standards of human rights are maintained.
Hill Dickinson LLP has developed a risk based approach to assess the possibility of Modern Slavery within our supply chain. The factors considered for this approach include for example; the country of origin and the nature of, and location from which, services are provided. This approach allows us to categorise suppliers and identify potential areas to assess for Modern Slavery.
We have issued Modern Slavery questionnaires to those of our existing suppliers that we have identified as high risk, in order to assess their current anti-Modern Slavery policies and controls. When responses are received, they are reviewed and the risk assessment of the supplier is updated accordingly. Where we have identified a potential risk, it is investigated and mitigated through activities such as enhanced due diligence.
Our Modern Slavery questionnaire will be issued to new suppliers of services assessed to be high risk during the on-boarding process.
The contractual terms and conditions that we put in place with our suppliers are being updated to include clauses that forbid the use of slavery and human trafficking.
We enforce a strict code of compliance and do not tolerate Modern Slavery within our supply chains. In the rare event that we become aware of a case of Modern Slavery, we will work with the supplier to implement remedial action. We expect our suppliers to engage with us constructively and responsibly, and to demonstrate their willingness to remedy issues in a timely manner. If we find evidence of a failure to comply with our policies we will immediately seek to terminate our relationship with the relevant supplier.
General awareness training is to be provided to those staff members who are involved in managing recruitment and our supply chains.
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Hill Dickinson's slavery and human trafficking statement for the financial year commencing 1st May 2015 and ending 30th April 2016.
Hill Dickinson LLP