Slavery & human trafficking

With fee income of less than £36 million Fox Williams LLP (FW) is not required to implement a modern slavery statement under section 54 of the Modern Slavery Act 2015.

As a responsible law firm we are rightly held to high standards in everything we do. We believe that our success in becoming the law firm of choice for our clients depends on our ability to inspire trust and earn the confidence of all our stakeholders. FW voluntarily implemented this modern slavery and human trafficking policy for a number of years before it was a requirement for us to do so.

This Policy applies to all employees, temporary or contract workers, consultants and partners of the firm from time to time (“staff”), regardless of seniority or position. It does not form part of the contractual documentation (whether a contract of employment or otherwise) of any member of staff, and may be amended or withdrawn at any time at the discretion of the firm.

1. Policy and voluntary slavery and human trafficking statement
   1. We oppose slavery and human trafficking in all its forms.
   2. We are committed to ethical trading principles and acting with integrity in all our business relationships.
   3. We are committed to implementing effective systems and controls to ensure slavery and human trafficking is not taking place in our supply chain.
2. Process – due diligence and risk assessment
   1. To help identify and monitor the risk of slavery and human trafficking of all of our existing and prospective in our supply chain we assess the risk they might employ labour in contravention of the Modern Slavery Act 2015. Each supplier will be categorised into high / medium or low risk. For those considered to be medium or high risk, we require them to have a policy or equivalent statement to mitigate the risk and to ensure compliance.
   2. We only employ agency workers through reputable employment agencies that adhere to our anti-slavery and human trafficking policy (or equivalent policies) where relevant and required. We will not use suppliers who do not adhere.
   3. Our risk assessment concludes that a vast majority of our suppliers are of low risk of non-compliance due to the nature of the goods or services being provided.
   4. Any breaches or concerns that a supplier might be in breach of the Modern Slavery Act 2015 are to be reported immediately to the Chief Operating Officer who reports to the Senior Partner and the Partnership Board.
3. Accountability
   1. Our guide to Employees sets out clear guidelines as to how we expect our people and stakeholders to act. We recognise the importance of respecting and promoting human rights both internally and externally.
   2. A culture of openness and accountability is essential in order to prevent unethical behaviour and to address it when it does occur. Our Whistleblowing Policy applies to all members of staff, regardless of seniority or position. It encourages members of staff to raise concerns on a range of matters where they consider, acting in good faith, that there has been a failure to adhere to legal obligations, which would include violations of the Modern Slavery Act, while making it clear they can do so without fear of reprisal or other detriment.
4. Effectiveness in combating slavery and human trafficking
   We use the following key performance indicators (KPIs) to measure how effective we have been at ensuring that slavery and human trafficking is not taking place in our business or supply chain:
   1. The percentage of suppliers and sub-contractors vetted for compliance with the modern Slavery Act 2015; and
   2. The number of reported breaches in each year.

   A log will be maintained to report on the KPIs and will be reported to the Partnership Board on an annual basis.

5. Training
   To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff working in procurement.

   We also require our business partners considered to be of medium to high risk of non-compliance to provide training to their staff and suppliers to have a Modern Slavery Act 2015 policy.