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Anti-Slavery and Human Trafficking Statement

Our purpose is to help our clients, our people and our communities to thrive. In support of this, we foster a diverse and inclusive culture that places respect and support for everyone at its core, not just for our own employees.

Our responsibility extends to ensuring that all our business and supply chains are free from slavery, servitude or exploitation of any individuals. As lawyers, we also help other businesses to identify and address key human rights risks.

I can confirm that we have not identified any examples of Modern Slavery within our business or supply chain in the last 12 months. As a responsible and accountable organisation, we will continue to focus on this critical issue in the year ahead as part of our commitment to ethical business conduct.

Keith Froud – Managing Partner – Eversheds Sutherland (International)

Background

This statement is published on behalf of Eversheds Sutherland (International) LLP and Eversheds Sutherland Legal Services Limited (the employing entity of Eversheds Sutherland (International) LLP), which have a turnover in excess of £36m. References in this statement to “we”, “us” and “our” are to both. The statement is made in accordance with Section 54 of the Modern Slavery Act 2015 (“the Act”) and covers the financial year from 1 May 2018 to 30 April 2019.This statement is published on behalf of Eversheds Sutherland (International) LLP and Eversheds Sutherland Legal Services Limited (the employing entity of Eversheds Sutherland (International) LLP), which have a turnover in excess of £36m. References in this statement to “we”, “us” and “our” are to both. The statement made in accordance with Section 54 of the Modern Slavery Act 2015 (“the Act”) and covers the financial year from 1 May 2018 to 30 April 2019.

Eversheds Sutherland is a global law firm with offices and related entities across the world. It employs 3570 people worldwide and operates in England and Wales through Eversheds Sutherland (International) LLP, a limited liability partnership registered in England and Wales. To find out more about its structure, what it does, and its values please click here.

As an office-based professional services organization we work with a range of suppliers. Our top areas of spend with suppliers are property and facilities management, and technology, with our spend being highly concentrated with our large tier 1 suppliers.

Anti-slavery

Our Approach to Modern Slavery

The Act defines modern slavery as slavery, servitude, forced and compulsory labour and human trafficking. There were an estimated 40.3 million people in slavery globally in 2016. In accordance with the United Nations Guiding Principles on Business and Human Rights (“UNGPs”) we recognize that combating slavery and trafficking requires a strict approach to due diligence activities and for a consistent risk based approach to be adopted across our business and our supply chains.

In our Business

We have a zero-tolerance approach to modern slavery in our organisation or our supply chains. We make it clear within our Anti-Slavery and Human Trafficking Policy and in the training delivered to staff that the prevention, detection and reporting of modern slavery in any part of our organization or supply chain is the responsibility of all those working for us or on our behalf. This policy is, and will continue to be, reviewed regularly and amended when necessary. The latest amendments were made in October 2018. The policy is also shared with all our suppliers.

As part of our due diligence process, we make sure key suppliers are aware of our policies, and adhere to the same high standards. As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we require potential key suppliers to complete a questionnaire during our procurement process which provides details of their own record in ensuring that there is no modern slavery in their business or supply chain. In a full tender exercise a second questionnaire is sent requiring further information regarding compliance with the Act.

Once a key supplier has been approved, we require them to provide documentary evidence of their compliance with the Modern Slavery Act and a contractual undertaking that they will comply with our Supplier Code of Conduct and Anti-Slavery and Human Trafficking Policy.

Having completed a supplier risk profiling program and identified the areas of our business where there may be heightened risks of modern slavery, we have developed an improved rolling audit or ‘health check’ of high risk suppliers. That process has been reviewed and updated in the last 12 months.

We assess the risk of modern slavery in our business and supply chain against the following criteria:

  • supplier type
  • geographical location
  • what the supplier tells us about the measures they have taken to ensure there is no modern slavery in their business and supply chain

We have monitored and assessed those property and facilities suppliers deemed to be at the highest risk based on the above criteria through monthly, quarterly, and annual governance meetings with those suppliers.

We ensure that our staff are aware of our approach to Modern Slavery by having a dedicated intranet page to enable and empower our staff to assist us in enforcing compliance with our Policy and our Supplier Code of Conduct. That page also contains links to our training on Modern Slavery so that they are able to review this whenever required.

We will not tolerate slavery and human trafficking within our supply chains. To that end, in the last 12 months we have updated the terms included within our contracts on this.

In the Wider Community

Throughout 2018 we continued to take part in The Law Firm Peer Learning Process to ensure that we and others within our industry have advanced our efforts to implement respect for human rights, driven increased engagement of the legal profession, established communities of practice and supported the legal profession and their clients in addressing human rights issues. That involvement culminated in a final report being delivered in January 2019.

We have also continued to be a leading provider of training and advice to our clients on the topic of modern slavery and have a designated Human Rights and Modern Slavery Hub on our website which demonstrates some of our work in this area. In the last 12 months we have raised over £5,000.00 for a leading charity countering modern slavery through the sales of our e-learning modules.

Our Ongoing Commitment

We remain committed to ensuring that there is no Modern Slavery within our business or our supply chain. Our plan for the next twelve months includes:

  • Delivering revised training to all our employees on identifying and reporting any concerns regarding modern slavery
  • Revising our due diligence process to include additional questions within our questionnaires and require additional documentary evidence of our suppliers’ commitment to eradicating modern slavery
  • Committing to a Service Level Agreement for any and all contact received though our whistleblowing procedures

Approval

This statement was approved by Keith Froud, Managing Partner (International) on 30 October 2019 on behalf of Eversheds Sutherland (International) LLP and Eversheds Sutherland Legal Services Limited.

Signature

Keith Froud
Managing Partner International
Eversheds Sutherland (International) LLP and Eversheds Sutherland Legal Services Limites

Modern Slavery Statement March 2018

This statement is made by Eversheds Sutherland (International) LLP and Eversheds Sutherland Legal Services Limited. It is a statement made in accordance with Section 54 of the Modern Slavery Act 2015 and covers the financial year from 1 May 2016 to 30 April 2017.

Eversheds Sutherland (International) LLP and Eversheds Sutherland Legal Services Limited sit under the Eversheds Sutherland brand. To find out more about our structure, what we do and our values please go to our about us

Our business is office-based and our primary supply chain categories support these operations.

We know that slavery, human trafficking, servitude and forced labour (“Modern Slavery”) is a global and increasing challenge for governments and business. Eversheds Sutherland (International) LLP has been at the forefront of providing advice and guidance to UK and international businesses. This has included:

  • Developing two e-learning modules to raise awareness of the issues;
  • Partnering with a leading charity countering modern slavery and generating income for them through the sales of our e-learning modules;
  • Organising thought leadership events including:
    • an event (Tools and implications for business one year on) with Rt Hon Fiona Mactaggart MP (then Chair of the Commons Select Committee) for tackling modern slavery and Nicholas Griffin QC; and
    • an event with Sir David Metcalf (Director of Labour Market Enforcement);
  • Bespoke training to in-house procurement, legal and compliance teams in various sectors;
  • Assisting clients with risk assessments of their organisational and supply chain risks and making recommendations; and
  • Webinars and briefings on modern slavery and business and human rights to local business networks through LexisNexis and at conferences and in-house counsel events.
  • Eversheds Sutherland (International) LLP has acted as an expert advisor to Shift and the Equality and Human Rights Commission in producing top level guidance to assist companies identifying, mitigating and reporting on their human rights impacts and activities. Our comprehensive survey “Human rights at work – on the right path” assessed levels of business engagement with human rights and the awareness and knowledge regarding new reporting obligations and provides guidance to companies reporting on human rights within their operations.

Our Policies on Slavery and Human Trafficking

  • Eversheds Sutherland (International) LLP and Eversheds Sutherland Legal Services Limited recognise their responsibility to be aware of their organisational and supply chain Modern Slavery risks. We have therefore taken the following steps:
  • In October 2016 we introduced a new Anti-Slavery and Human Trafficking Policy. Our policy outlines our zero tolerance approach to Modern Slavery of any kind within our operations and supply chain and has been approved by the firm’s Executive.  Our policy sets out the standards we expect of everyone working with us or on our behalf to support and uphold our policy commitments and provides guidelines for employees, partners and agency workers to report any suspicions or concerns relating to compliance with the policy;
  • Revised our whistleblowing policy to provide a mechanism for reporting any concerns relating to Modern Slavery in confidence. This policy is published on our intranet site; and
  • Introduced and published internally our Supplier Code of Conduct on Slavery and Trafficking.

Risk Assessment Processes

  • Reflecting the United Nations Guiding Principles on Business and Human Rights (“UNGP’s”) we recognise that due diligence activities to combat slavery and trafficking are required across our supply chains and the need for a consistent risk based approach to be adopted. In 2016 we carried out a supplier risk profiling programme and we identified the following risk categories to assess heightened risks of modern slavery:
  • Supplier type – cleaning, catering,  facilities management,  travel,  IT support/equipment and professional services;
  • Geographical location;
  • The availability of documentation evidencing the supplier’s compliance procedures; and
  • Supplier willingness to provide contractual assurances.

Due Diligence Processes

  • We are undertaking in full or in part the following:
  • The updating of our contractual terms with suppliers to include appropriate Modern Slavery provisions;
  • The inclusion of a statement on our commitment to Modern Slavery in our standard terms of engagement with our clients;
  • The requirement for suppliers to provide, where required, documentary evidence of their compliance with the Modern Slavery Act;
  • Confirmation from suppliers that they have read and will comply with our Supplier Code of Conduct and Anti-Slavery and Human Trafficking Policy; and
  • Upfront questioning of suppliers during the tender process and a programme of post appointment reviews of compliance.

Training to raise awareness of Modern Slavery and Human Trafficking

  • Training has been given to members of staff on Modern Slavery and on the requirements of our Anti-Slavery and Trafficking Policy and the Supplier Code of Conduct.
  • We have also engaged the services of a third party consultant to work with us to develop human rights training and to produce a guide for our Corporate and Commercial lawyers to raise awareness of the UNGP’s and human rights issues when advising on corporate due diligence. That training has been rolled out to the relevant lawyers.
  • Going forwards, key staff will also be required to undertake our modern slavery e-learning which we reference elsewhere in this statement.

Measuring Effectiveness – Performance Indicators

  • In order to monitor the effectiveness of the steps we have taken to seek to prevent slavery and trafficking taking place in our business and supply chains we are or will be:
  • Regularly reviewing the effectiveness of our Anti-Slavery and Trafficking Policy and the Supplier Code of Conduct;
  • Testing the awareness of staff on the risks of Modern Slavery and the firm’s internal processes to address this, as part of a rolling risk and training programme;
  • Continuing to monitor and consider responses of those suppliers with whom we have and are corresponding with in relation to our Modern Slavery requirements;
  • Continuing with our post appointment audits of suppliers;
  • Introducing an annual rolling audit of suppliers; and
  • Continuing with our supplier risk profiling programme.

Modern Slavery Statement November 2016

This statement is made by Eversheds Sutherland. It is a statement made in accordance with Section 54 of the Modern Slavery Act 2015 and covers the financial year from 1 May 2015 to 30 April 2016.

Eversheds Sutherland is one of the largest full service law firms in the world and provides legal and consultancy services across 25 offices in the UK and internationally. Eversheds Sutherland had an annual turnover in 2014/2015 of £379 million and employs circa 2800 people in our UK and international operations. To find out more about what we do and our values, please go to our about us page. We know that slavery, human trafficking, servitude and forced labour (Modern Slavery) is a global and increasing challenge for governments and business. Eversheds Sutherland has been at the forefront of providing advice and guidance to UK and international businesses through the delivery of training, webinars and thought leadership events. Eversheds Sutherland have acted as an expert advisor to Shift and the Equality and Human Rights Commission in producing top level guidance to assist companies identifying, mitigating and reporting on their human rights impacts and activities. Our comprehensive survey “Human rights at work – on the right path” assessed levels of business engagement with human rights and the awareness and knowledge regarding new reporting obligations and provides guidance to companies reporting on human rights within their operations.

Our Policies on Slavery and Human Trafficking

As a business we recognise our responsibility to be aware of the risks of Modern Slavery within our own organisation and supply chain. We have, therefore, taken the following steps:

  • In October 2016, we introduced a new Anti-Slavery and Human Trafficking Policy. Our policy outlines our zero tolerance approach to Modern Slavery of any kind within our operations and supply chain and has been approved by the Partnership’s Executive. Our policy sets out the standards we expect of everyone working with us or on our behalf to support and uphold our policy commitments and provides guidelines for employees, partners and agency workers to report any suspicions or concerns relating to compliance with the policy;
  • We also have a clear whistleblowing policy which is published on our intranet site and if there are any concerns relating to Modern Slavery these concerns can be raised in confidence without fear as part of our whistleblowing procedure. Our whistleblowing policy has been modified to take account of the Modern Slavery Act 2015. All reports of Modern Slavery will be fully investigated and appropriate remedial actions taken.

Risk Assessment Processes

Reflecting the United Nations Guiding Principles on Business and Human Rights, (UMGP’s) our due diligence activities to combat slavery and trafficking, described below, are risk based and will in future correspond with the level of risk identified. As such, we have undertaken or begun the following risk assessment processes during the period to inform our due diligence approach:

  • We have undertaken a supply chain risk assessment of Eversheds Sutherland Modern Slavery risks with over 5,000 suppliers to develop a prioritisation list of high risk suppliers in respect of modern slavery areas. We assess risk using key information such as the supplier type and geographical location and we have also reviewed independent and regulatory employment risk assessment resources . The results have produced supplier risk ratings enabling us to prioritise future due diligence within our supply chain.
  • In addition our tier 1 contractors, selected on the basis of contract size and revenue, are all established businesses who are required to comply with the Modern Slavery Act reporting obligations in their own right.

Due Diligence Processes

In order to seek to prevent slavery and trafficking in our business and supply chains we have begun a due diligence process during this period. Steps undertaken or begun include:-

  • The publication and adoption of a Supplier Code of Conduct on Slavery and Trafficking. This has been published on our intranet and as indicated above has been communicated to main contractors who have been asked to confirm that they will make a commitment to comply with the standards set out in the Code.
  • From October 2016 onwards, new third party relationships will be subject to specific questioning regarding compliance with the Modern Slavery Act and our Code of Conduct and we are modifying our procurement procedures to address the risk of slavery and trafficking. We have also updated our contractual terms to include appropriate Modern Slavery provisions.
  • We will be reviewing any potential higher risk relationships based on our risk assessment process outcome and determining the extent to which it is appropriate to take any further precautionary measures to minimise the risk of slavery and trafficking where we have a direct relationship with those organisations.

Training to raise awareness of Modern Slavery and Human Trafficking

We are in the process of training our key staff on Modern Slavery and on the requirements of our Anti-Slavery and Trafficking Policy and the Supplier Code of Conduct. We have also trained them in relation to anti-slavery and trafficking due diligence in the procurement process. Eversheds Sutherland has also engaged the services of a third party consultant to work with us to develop human rights training and to produce a guide for our Corporate and Commercial lawyers to raise awareness of the UNGP’s and human rights issues when advising on corporate due diligence.

Measuring Effectiveness – Performance Indicators

In order to monitor the effectiveness of the steps we have taken to seek to prevent slavery and trafficking taking place in our business and supply chains we intend to:-

  • Review the effectiveness of our Anti-Slavery and Trafficking Policy and Supplier Code of Conduct;
  • Ensure that all key staff are trained in relation to the Modern Slavery Act and slavery and trafficking risks on an ongoing basis.
  • Develop appropriate systems to ensure that we engage appropriately with medium and higher risk suppliers based on our risk assessment process, to ensure they are aware of Eversheds Sutherland’s zero tolerance approach to Modern Slavery whilst ensuring that we take appropriate measures to encourage and persuade them to adopt their own measures to minimise the risks of slavery and trafficking within their own organisations;
  • Monitor and consider responses of those suppliers with whom we correspond to raise awareness of the Modern Slavery Act and to explain our policy commitments and the obligations under our Code of Conduct on slavery and trafficking.
  • Assess and consider the appropriateness of developing further measures including audit with specific suppliers where we assess that there may be a heightened risk of slavery and trafficking within those organisations;