Slavery and Human Trafficking Annual Statement, Financial Year 1 January - 31 December, 2017
This statement is made by Dechert LLP (“Dechert”, the “firm” and “we”) in accordance with Section 54 (1) of the Modern Slavery Act 2015 (the “Act”) for the financial year ending 31 December 2017. It has been approved by the London Management Committee on behalf of the partners, signed by a designated member and published on the firm’s website with a link in a prominent place on the homepage at www.dechert.com.
- Dechert 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 its business or in any of its supply chains. This is integral to our Firm Guiding Principles and our Personal Commitments, which underpin all our activities. This statement, the second the firm is making under the Act, sets out the steps we have taken to address the risks of slavery.
Dechert is established and operates as a limited liability partnership under English law, authorised and regulated by the Solicitors Regulation Authority. It is a part of Dechert LLP, a global law firm of some 1,000 lawyers with highly ranked practices in corporate and securities, complex litigation, finance and real estate, and financial services and asset management, with 27 offices throughout the United States, Europe, Asia and the Middle East. The firm is owned by the partners and has a global management team which ensures that all its offices work together effectively to achieve its goals. Further information can be found at www.dechert.com.
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, they have been treated in the same way as the firm’s other suppliers.
As a professional services provider, Dechert predominantly employs and contracts the services of professionally qualified people. The firm also contracts office support services including for catering, office supplies, IT, recruitment, property, cleaning, security, maintenance and construction services. Dechert’s suppliers outside the UK are primarily other Dechert offices which in turn contract a similar range of support services locally.
Our Modern Slavery Policy
Dechert’s London Management Committee has adopted and promulgated a Modern Slavery Policy (the “Policy”). This commits the firm to preventing any slavery in its business and requiring the same standards of its suppliers. The Policy applies to all employees, associates, and partners (“Dechert Personnel”) and to all those who perform services for or on behalf of Dechert. The partners of the firm have overall responsibility for the Policy. They have delegated responsibility for overseeing, evaluating and updating it to the Compliance Officer for Legal Practice.
The Policy makes clear that in addition to penalties that may be imposed by law on individuals or on Dechert, any Dechert Personnel who violate the Policy will be subjected to disciplinary measures up to and including termination of employment. Dechert may seek to terminate its relationship with any supplier that is found to be in violation of the Policy. Dechert will refer all appropriate matters to the 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 the firm’s business or supply chains. The firm is 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 the firm’s business or in any of its supply chains, including if the report is mistaken.
The Policy sets out requirements for regular training, assessing risks, due diligence procedures, performance indicators and an annual review. These are addressed below.
Due Diligence Procedures
Dechert aims to partner with suppliers committed to the same strict principles and high ethical standards that the firm adheres to itself.
The firm has designed due diligence procedures to establish, assess, monitor and reduce areas of potential risk in its business and supply chains, and to address any reports of slavery occurring. As the basis for these procedures, the firm first ensures that it can account for each step of its supply processes and that it knows who is providing goods and services to it at all times.
The firm takes the following actions with respect to all its direct suppliers in the UK:
- when entering into arrangements with new suppliers, the firm assesses them for any indicators that slavery might occur in their business or their supply chains;
- suppliers are given a copy of the firm’s Modern Slavery Policy and informed in writing that the firm does not tolerate any form of slavery in their business or in any part of their supply chains;
- suppliers are asked to sign the firm’s Supplier Code of Conduct to acknowledge that they are working on the basis required by the firm. This sets out fundamental ethical requirements that they should adhere to, 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 the inclusion of relevant provisions in the letters of engagement;
- the firm imposes contractual obligations on suppliers requiring that they comply with the firm’s Modern Slavery Policy and Supplier Code of Conduct and warrant that their business and, to the best of their knowledge, their own supply chain do not use slavery. They may also be required to provide a statement to the firm setting out the actions they are taking to prevent any occurrence of slavery. The firm will review all responses and take appropriate follow-up action to resolve any concerns that may arise;
- the firm reserves the right to audit any of its 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, the firm requires that immediate remedial action is taken to address it and will provide appropriate support to achieve the safest outcome for potential victims. The firm expects its suppliers to engage constructively and responsibly, and to remedy any issues in a timely manner. In the event of failure to resolve the situation rapidly and satisfactorily, the firm will terminate the contract;
- in the event of any allegations emerging of slavery occurring in a part of the firm’s supply chain, including from whistle-blowers, the firm will comprehensively and urgently investigate any such allegations and, if any slavery is identified, will take immediate action as set out above.
As a result of conducting these due diligence procedures, the firm continues to assess the risk of slavery in its own business as very low, particularly since its recruitment procedures, employment terms and internal policies are maintained and implemented in full compliance with all applicable employment laws and regulations. The firm invests heavily in the professional development, health and wellbeing of all its 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).
The risk of slavery in the firm’s supply chains continues to be assessed as low, with the principal area of risk residing in the supply chains of the firm’s 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, the firm did not identify any incidence or significant risk of slavery in its 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.
We have assessed the firm’s performance over the financial year covered by this statement against the key performance indicators defined in the Policy as follows:
a) The firm’s recruitment, employment and internal policies remain in full compliance with all applicable laws and regulations.
- This was fully achieved.
b) All new suppliers sign the firm’s Supplier Code of Conduct.
- All of our new suppliers signed the Code.
c) All suppliers respond satisfactorily to the firm’s request for a statement on their actions to prevent slavery and any concerns are satisfactorily and promptly resolved.
- The firm did not have cause to require such a statement from a supplier. We are continuing to be alert to a need to exercise this requirement in reviewing new suppliers and those subject to contract renewal.
d) Any concerns raised as a result of audits or allegations are promptly followed-up and resolved.
- The firm 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.
e) All relevant staff in Human Resources, Facilities Management, IT, Finance, Marketing and Administration receive appropriate training and awareness-raising.
- This was fully achieved. The firm is continuing to develop awareness of slavery-related issues amongst relevant staff and with key suppliers.
Dechert continues 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:
- requesting all our major suppliers to confirm on an annual basis that they are in full compliance with our Policy;
- imposing the same requirements on our significant global suppliers as we currently apply to our UK suppliers;
- establishing a Steering Group, meeting quarterly to pro-actively oversee the implementation of the Policy;
- partnering with more community organisations such as Business in the Community and Working Families;
- exploring accreditation as a Living Wage Employer by the Living Wage Foundation;
- incorporating training on the Policy into the induction training for all new staff and conducting annual awareness-raising sessions for all staff.
We aim to report progress on these and other potential developments in our future statements.
Approved by: the London Management Committee on behalf of the partners
Signed: Miriam Gonzalez, member of the London Management Committee
26 June 2018