Anti-slavery and human trafficking policy

Please click here to read our Modern Slavery Act statement.

Modern slavery is a crime and a violation of fundamental human rights. All types of modern slavery have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We are committed to acting ethically and with integrity in all our business dealings and relationships and to ensure modern slavery is not taking place anywhere in our own business, or in any of our supply chains.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our business relationships, consistent with our disclosure obligations under the Modern Slavery Act 2015. As part of this process, we will undertake an annual review of our supply chain to identify and assess potential risk areas and maintain a register detailing the same. We expect the same high standards from all our subcontractors, suppliers and other business partners and will make this a contractual term in our agreements with suppliers wherever possible.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, interns, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of any employee's contract of employment and we may amend it at any time.

Responsibility for the policy
The management of the firm has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The legal department has primary and day-to-day responsibility for implementing this policy, but the procurement team within the finance department will be responsible for reviewing the risk profile of our supply chain to ensure that any procedures implemented are effective in countering modern slavery.

Compliance with the policy
Everyone working for us must ensure that they read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control.  They are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Everyone working for us is encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage with the legal department.

If someone working for us believes or suspects a breach of this policy has occurred or that it may occur they must notify the legal department as soon as possible. If they are in any doubt about whether a particular act or working conditions in any of our business relationships may contravene any aspect of this policy then we recommend that they err on the side of caution and report it to the legal department.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith in accordance with the firm's whistleblowing policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our business or in any of our supply chains.

Communication and awareness of this policy
Our zero-tolerance approach to modern slavery should be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Breaches of this policy
Any employee who breaches this policy could face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.