Slavery and Human Trafficking Annual Statement, Financial Year 1 January - 31 December, 2019
This statement is made by Dechert LLP (“Dechert LLP UK”) in accordance with Section 54 (1) of the Modern Slavery Act 2015 (the “Act”) for the financial year ended 31 December 2019. Dechert LLP UK is a limited liability partnership registered in England & Wales (Registered No. OC306029) and is authorised and regulated by the Solicitors Regulation Authority of England and Wales. The registered address of Dechert LLP UK is 160 Queen Victoria Street, London EC4V 4QQ, United Kingdom. A list of names of the members of Dechert LLP UK (who are referred to as “partners”) is available for inspection at the above address.
This statement has been approved by the London Management Committee on behalf of Dechert LLP UK, signed by a designated LLP member and published on the firm’s website with a link in a prominent place on the homepage at www.dechert.com.
Dechert LLP UK is committed to acting in full compliance with the Modern Slavery Act 2015 and to ensuring that any form of forced or bonded labour or human trafficking (collectively referred to as “Slavery” in this statement) is not taking place in any part of our business or in any of our supply chains. This is integral to our Firm Guiding Principles and our Personal Commitments, which underpin all our activities. This statement sets out the steps we have taken to address the risks of Slavery.
Our Organisational Structure and Supply Chains
The law firm Dechert is a combination of separate limited liability partnerships and other entities registered in various jurisdictions across 26 offices. Dechert has more than 900 qualified lawyers and 700 staff members in its offices in Belgium, China, France, Germany, Hong Kong, Ireland, Kazakhstan, Luxembourg, Russia, Singapore, the United Arab Emirates, the UK and the USA.
The firm is owned by its partners, and the firm’s senior executive body, the Policy Committee, ensures that all its offices work together effectively to achieve its goals. In the UK, the London Management Committee is responsible for managing and administering Dechert LLP UK. The firm also operates a number of practice groups across its various offices, which consist of lawyers dedicated to practising in a specific area of the law. Further information about Dechert LLP UK and the firm more generally can be found at www.dechert.com. There was no significant change in the firm’s structure during the period covered by this statement.
Dechert’s offices outside the UK do not supply goods or services in the UK independently. They are therefore not required by the Act to publish an annual statement; but since they supply services to Dechert LLP UK, they have been treated in the same way as our other suppliers.
Dechert LLP UK’s supply chain may be divided broadly into three categories:
Professional Services: Dechert LLP UK predominantly engages third party professional service providers, for example barristers or accountancy firms. Our requirements with respect to the standards these service providers are expected to meet are set out in the relevant provisions in our letters of engagement. The relationship with a professional service provider is managed by the practice group within Dechert LLP UK that has engaged with that particular service provider;
Support Services: Dechert LLP UK also contracts with various third party office support services, including for catering, office supplies, IT, recruitment, property, cleaning, security, maintenance and construction services. The terms on which we contract with these service providers are set out in our contracts and in our Supplier Code of Conduct, which all new suppliers to Dechert LLP UK are required to sign. The relationship with an office support service provider is managed by the head of the administrative team within Dechert LLP UK who engaged that service provider; and
Outside the UK: Dechert LLP UK’s suppliers outside the UK are primarily other Dechert offices, which in turn contract a similar range of support services locally. We have written to all Dechert’s overseas offices to set out our requirements with respect to the standards they are expected to meet. These relationships are also managed by the heads of our administrative teams.
Our Modern Slavery Policy
The London Management Committee of Dechert LLP UK has adopted and promulgated a specific Modern Slavery Policy (the “Policy”), which draws on best-practice guidance published by the Government and specialist civil society organisations and is aligned closely with other related firm policies (e.g. employment, procurement, etc.). The Policy is readily available to all staff on the firm’s intranet.
The Policy commits Dechert LLP UK to preventing any Slavery in its business and requiring the same standards of its suppliers. The Policy applies to all partners and employees of Dechert LLP UK (collectively, “Dechert Personnel”) and to all those who perform services for or on behalf of Dechert LLP UK. The partners of Dechert LLP UK have overall responsibility for the Policy; they have delegated responsibility for overseeing, evaluating and updating the Policy to the office of the firm’s International General Counsel.
The Policy makes clear that, in addition to penalties that may be imposed by law on individuals or on Dechert LLP UK, any Dechert Personnel who violate the Policy will be subject to disciplinary measures up to and including termination of employment. We may seek to terminate our relationship with any supplier who is found to be in violation of our Supplier Code of Conduct. We will refer all appropriate matters to the relevant enforcement authorities.
Dechert Personnel and suppliers are held responsible for reporting at the earliest opportunity any activity that might lead to, or suggest, a breach of the Policy in any part of our business or supply chains. We are committed to ensuring that no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that Slavery of whatever form is or may be taking place in any part of our business or in any of our supply chains, including if the report is mistaken.
The Policy sets out requirements for due diligence procedures, assessing risks, regular training, performance indicators and an annual review. These are addressed in more detail below.
Due Diligence Processes
We aim to partner with suppliers committed to the same strict principles and high ethical standards that the firm adheres to itself.
We have designed due diligence procedures to establish, assess, monitor and reduce areas of potential risk in our business and supply chains, and to address any reports of Slavery. As the basis for these procedures, we first ensure that we can account for each step of our supply processes and that we know who is providing goods and services to us at all times.
We take the following actions with respect to all our direct suppliers in the UK:
- new suppliers are given a copy of the Policy and informed in writing that we do not tolerate any form of slavery in our business or in any part of our supply chains;
- new suppliers are asked to sign our Supplier Code of Conduct to acknowledge that they are working on the basis required by us. This sets out fundamental ethical requirements to which they should adhere, including that they will not use any form of forced, bonded or child labour, and requires that they impose equivalent standards on their own suppliers. In the case of suppliers of professional services, this requirement is met by including relevant provisions in our letter of engagement with the supplier;
- all relevant suppliers (over £50,000 per annum) are requested to confirm on an annual basis that they are in full compliance with the Policy;
- we impose contractual obligations on relevant suppliers requiring that they comply with the Policy and our Supplier Code of Conduct and warrant that their business and, to the best of their knowledge, their own supply chains do not use Slavery. They may also be required to provide a statement setting out the actions they are taking to prevent any occurrence of Slavery. We review all responses and take appropriate follow-up action to resolve any concerns that may arise;
- we reserve the right to audit any of our suppliers and, as appropriate, will require them to take specific measures to ensure that the risk of Slavery is significantly reduced. In cases where Slavery is identified, we require immediate remedial action be taken to address it and will provide appropriate support to achieve the safest outcome for potential victims. We expect our suppliers to engage constructively and responsibly, and to remedy any issues in a timely manner. In the event of a failure to resolve the situation rapidly and satisfactorily, we will terminate the contract;
- we impose the same requirements on our significant global suppliers as we apply to our UK suppliers; and
- if any allegations emerge of Slavery occurring in a part of our supply chain, including from whistle-blowers, we will comprehensively and urgently investigate the allegations and, if any Slavery is identified, will take immediate action as set out above.
Risk assessment and management
As a result of conducting these due diligence procedures, we continue to assess the risk of Slavery in our own business as very low, particularly since our recruitment procedures, employment terms and internal policies are maintained and implemented in full compliance with all applicable employment laws and regulations.
We invest heavily in the professional development, health and wellbeing of all our staff. We pay all employees in the London office above the London Living Wage (except for our two-week vacation students, who receive an allowance). We are also exploring accreditation as a Living Wage Employer by the Living Wage Foundation, as well as partnering with community organisations such as Business in the Community and Working Families.
The risk of Slavery in Dechert LLP UK’s supply chains continues to be assessed as low, with the principal area of risk residing in the supply chains of our direct suppliers and contractors of office support services, particularly those in higher-risk jurisdictions outside the UK. This risk is managed through the due diligence procedures set out above.
For the financial year covered by this statement, we did not identify any incidence or significant risk of Slavery in our business or supply chains. But it is fully recognised that this task requires constant vigilance.
In accordance with the firm’s Policy, relevant staff in Human Resources, Facilities Management, IT, Finance, Marketing and Administration have received appropriate training and awareness-raising on the global and UK challenges posed by slavery, the requirements of the Act, the firm’s Policy and the implementation of the due diligence procedures. Discussions held during the training were taken into account in the development and improved implementation of the Policy. All staff have been briefed on the main requirements of the Policy.
Effectiveness Measured Against Key Performance Indicators
We have assessed our performance over the financial year covered by this statement against the key performance indicators defined in the Policy as follows:
- Dechert LLP UK’s recruitment, employment and internal policies remain in full compliance with all applicable laws and regulations: This was fully achieved.
- All relevant suppliers agree to our Supplier Code of Conduct and Policy: The relevant suppliers either agreed by returning a signed copy, or agreed by continuing to provide their services after receiving the Code and Policy.
- All suppliers respond satisfactorily to our request for a statement on their actions to prevent Slavery and any concerns are satisfactorily and promptly resolved: We did not have cause to require such a statement from a supplier. We remain alert to the potential need to exercise this requirement when reviewing new suppliers and those subject to contract renewal.
- Any concerns raised as a result of audits or allegations are promptly followed-up and resolved: We did not have cause to conduct an audit and no allegations were made. We remain alert to the potential need to conduct audits or to investigate allegations in the future.
- All relevant staff in Human Resources, Facilities Management, IT, Finance, Marketing and Administration receive appropriate training and awareness-raising: We are continuing to develop awareness of Slavery-related issues amongst relevant staff and with relevant suppliers.
We continue to look for ways to improve on these actions to ensure that our Policy and its implementation are robust, effective, proportionate and focused on identifying and rapidly addressing the risks of Slavery wherever they occur in our business or supply chains. Options under active consideration include:
- Becoming accredited by the Living Wage Foundation;
- Providing training to all new employees as part of their induction to the firm; and
- Reviewing our Policy to ensure it is in line with best practice.
We aim to report progress on these and other potential developments in our future statements.
This statement was formally approved on 15 October 2020 by the London Management Committee on behalf of the partners of Dechert LLP UK.
Signed: London Management Committee
Date: 15 October 2020