Modern Slavery

This statement is made by Bryan Cave Leighton Paisner LLP, a law firm and limited liability partnership registered in England and Wales and authorised and regulated by the Solicitors Regulation Authority (England and Wales). The statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 for the financial year ending 30 April 2018. It sets out the overall commitment and steps taken to ensure that slavery and human trafficking are not present in its business or direct supply chain.

BCLP Group structure 

On 1 April 2018, Berwin Leighton Paisner LLP (“BLP LLP”) combined with Bryan Cave LLP, and BLP LLP changed its name to Bryan Cave Leighton Paisner LLP  (“BCLP UK”) .

The Bryan Cave Leighton Paisner Group (“BCLP Group”) has 31 offices in 11 countries and provides legal and related services to corporates and individuals. A list of the BCLP Group entities (“BCLP Firms”) and legal and regulatory information regarding them (including corporate registration details, contact details, list of Partners and information about the way the BCLP Firms and their lawyers are regulated and insured, as appropriate) is contained in the legal notices section of our website. BCLP UK continues to be required under the Act to publish a statement.

The BCLP Group is committed to carrying on its business in a responsible and ethical manner that respects the rights and dignity of individuals and the communities where it operates and provides its services.  The BCLP Group has a zero tolerance policy concerning modern slavery and human trafficking and expects the same high standards and commitment from those it does business with. As part of BCLP UK’s ongoing commitment to take steps towards ensuring there is no risk of modern slavery and human trafficking in its operations and supply chain, we will be reviewing our approach in light of our post-combination structure, including relevant business and operational profile and relationships, and will seek to address these issues in future statements.

Given the timing of the completion of the combination, this statement focuses on the efforts of the UK operations of BCLP UK up to 1 April 2018. BCLP UK had a consolidated global turnover of £264m for the financial year ending 30 April 2018 and employed over 1200 staff.  

Our approach

To properly and transparently address the risks of modern slavery we have developed a systematic, risk based approach to identifying and assessing the risk of modern slavery and human trafficking within our business and direct supply chain.

As a business which is regulated, has a zero tolerance approach to modern slavery and human trafficking and comprehensive employment policies and practices (including diversity and inclusivity, equal opportunities and non-discrimination, flexible working and anti-harassment), BCLP UK has  assessed its own business as low risk for modern slavery and human trafficking issues.

We are committed to assessing any situations of concern regarding modern slavery and human trafficking on a case by case basis. Our Whistleblowing Policy provides a channel of communication for staff who have concerns; we have a Complaints Policy in place should clients wish to make a complaint; and our Supplier Code encourages suppliers to raise any issues of concern with us. BCLP UK’s Compliance Officer for Legal Practice (a position which is mandatory under applicable regulation) is also a key point of contact both internally and externally and has a regulatory duty to ensure that BCLP UK takes all reasonable steps to comply with its statutory obligations.

In light of the above, over the last year, our focus has been and continues to be on:

1. BCLP UK’s operations in England which is the location of our largest office with the greatest number of staff and the most significant proportion of our business and turnover;
2. our core legal services business; and
3. our direct commercial supply chain.

Report on KPIs and next steps

In the last financial year ending 30 April 2018 we have progressed a number of initiatives including:

• reviewed the way in which we resource the on-boarding and management of our suppliers
• risk rated over 700 suppliers for the UK office
• worked towards embedding our commercial supplier on-boarding and contract management approach beyond our UK focused initial phase to identify material commercial suppliers to our non-UK offices
• reviewed and updated our procurement process to ensure that addressing the risk of modern slavery and human trafficking is incorporated into our approach to ad hoc and low value suppliers
• reviewed and updated our internal resources to enable staff to manage direct commercial supplier relationships
• continued to embed our supplier on-boarding and contract management approach which promotes responsible and ethical relationships, by improving the skills and capacity of our UK based staff who deal with our direct commercial suppliers, providing staff training on our mandatory commercial supplier on-boarding process
• continued to promote our Ethical Business Principles (which were approved by the BLP LLP Board in 2016)
• continued to advise and work with clients in a number of sectors to develop their approach to managing the risk of modern slavery and human trafficking and broader human rights issues such as the implementation of UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct
• continued to raise awareness and sharing of knowledge and best practice across the legal profession in respect of modern slavery, human rights and responsible business practices issues by:
  • contributing to the development of International Bar Association guidance and tools on Human Rights Due Diligence for Corporate and Commercial transactions and training programs;
  • participating in a Law Firm Peer Learning Process to discuss emerging best practice for identification and management of modern slavery and human rights risk issues in our sector;
  • supporting the development of Manchester University’s Business and Human Rights Catalyst, including an inter-disciplinary executive education course; and
  • speaking at global business and human rights conferences and events, including the UN Annual Forum on Business and Human Rights in Geneva in December 2017.

We have found no issues in relation to modern slavery and human trafficking related to our direct commercial suppliers in the context of goods and services supplied to BCLP UK in England.

Next steps

As a result of the combination, the accounting year end of BCLP UK has changed from 30 April to 31 December. These next steps are therefore relevant to the period from 1 May 2018 to 31 December 2018.

During the course of that period we aimed to:

• begin a review of our approach to the risk of modern slavery and human trafficking in light of the combination and resulting change in group structure and scope of operations;
• refine our existing commercial supplier on-boarding and contract management approach;
• begin implementation of new contract management software;
• begin to review our commercial supplier on-boarding and contract management approach for offices outside of the UK;
• continue our dialogue with other international law firms about responsible and ethical business and supply chains with the aim of putting relevant peer learning into practice ourselves;
• contribute to the legal sector’s engagement with this issue by contributing to initiatives and speaking at global business and human rights conferences and events; and
• provide advice to and work with our clients and other entities with whom we have business relationships about how to eradicate the risk of modern slavery and human trafficking in their businesses and supply chains.

Date - 1.2.19

Lisa Mayhew

Designated member of Bryan Cave Leighton Paisner LLP

Note: On 1 April 2018, Bryan Cave LLP combined with Berwin Leighton Paisner LLP (“BLP LLP”), and BLP LLP changed its name to ‘Bryan Cave Leighton Paisner LLP’ (“BCLP UK”).

The statement below was published by BLP LLP prior to the completion of the combination, and contains references to the BLP Group’s pre-combination name and structure, correct as at the date of publication. As part of BCLP UK’s ongoing commitment to take steps towards ensuring there is no risk of modern slavery in its operations and supply chain, it will be reviewing its approach in light of the post-combination structure, including relevant business and operational profile and relationships, and will seek to address these issues in future statements. 

This statement is made by Berwin Leighton Paisner LLP (BLP) pursuant to section 54(1) of the Modern Slavery Act 2015 for the financial year ending 30 April 2017. It sets out the overall commitment and steps taken by BLP to ensure that slavery and human trafficking are not present in our business or direct supply chain.

BLP GROUP STRUCTURE

BLP is a law firm and limited liability partnership registered in England and Wales and is authorised and regulated by the Solicitors Regulation Authority (England and Wales).

The Berwin Leighton Paisner Group, which provides legal and related services to corporates and individuals had a consolidated global turnover of £254m for the financial year ending 30 April 2017 and employs over 1200 staff. For the purposes of this statement, “BLP Group”  means Berwin Leighton Paisner LLP, Berwin Leighton Paisner (Services), Berwin Leighton Paisner (Germany) LLP, Berwin Leighton Paisner (HK) LLP in association with Haley Ho & Partners, Goltsblat BLP LLP and Berwin Leighton Paisner (Myanmar) Limited. None of the entities within the BLP Group (other than BLP) fall within the reporting obligation at this time.

The BLP Group is committed to carrying on its business in a responsible and ethical manner that respects the rights and dignity of individuals and the communities where it operates and provides its services.  The BLP Group has a zero tolerance policy concerning modern slavery and expects the same high standards and commitment from those it does business with.

OUR APPROACH

As an international law firm the BLP Group’s operations and suppliers are based all over the world. To properly and transparently address the risks of modern slavery we have developed a systematic, risk based approach to identifying and assessing the risk of modern slavery within our business and direct supply chain.

As a business which is regulated and which has a zero tolerance approach to modern slavery and comprehensive employment policies and practices (including diversity and inclusivity, equal opportunities and non-discrimination, flexible working and anti-harassment), we have assessed our own business as low risk for modern slavery and human trafficking issues.

Our initial focus has been, and will continue to be, on:

1. our operations in England which is the location of our largest office with the greatest number of staff and the most significant proportion of our business and turnover; 
2. our core legal services business; and 
3. our direct commercial supply chain.

In the last financial year ending 30 April 2017 we have:

• reviewed and revised existing internal policies, including our Professional Practice Principles and Whistleblowing Policy (which defines our internal behavioural expectations), our Global Limits of Authority Policy (which sets out contract authorisation principles) and our Health & Safety Policy, which in conjunction with other processes are intended to create an holistic and integrated policy approach across our business concerning the management of modern slavery risks. 
• published our Ethical Business Principles (which were approved by the BLP Board) internally
• established a mandatory commercial supplier on-boarding process (initially for our UK offices as a pilot phase) which promotes responsible and ethical relationships
• established an internal portal equipped with tools and resources to enable staff to engage and manage direct commercial supplier relationships, including a supplier questionnaire 
• developed and are seeking to introduce new contractual clauses to address legal and regulatory requirements in accordance with our policy/risk assessment approach 
• published a Supplier Code of Conduct (which was approved by the BLP Board) as part of our direct commercial supplier management approach 
• continued to improve the skills and capacity of our UK based staff who deal with our direct commercial suppliers. This education and training has increased awareness of the risk of modern slavery and human trafficking across BLP and particularly amongst these key staff
• undertaken risk assessments on direct commercial suppliers engaged by the UK offices to identify potential or actual risks concerning modern slavery  
• promoted and contributed to the legal sector’s engagement with, awareness raising and sharing of knowledge and best practice in respect of modern slavery, human rights and responsible business practices issues, by contributing to the development of International Bar Association guidance and tools on Human Rights Due Diligence for Corporate and Commercial transactions; speaking at global business and human rights conferences and events, including the Annual UN Forum on Business and Human Rights
• taken part in a peer learning process with a number of other international law firms to discuss emerging best practice for identification and management of modern slavery risk issues in our sector.

To date we have not discovered any issues of concern. Moving forward, we are committed to assessing any situations of concern regarding modern slavery and human trafficking on a case by case basis. Our Whistleblowing Policy provides a channel of communication for staff who have concerns; we have a Complaints Policy in place should clients wish to make a complaint; and our Supplier Code encourages suppliers to raise any issues of concern with us. BLP’s Compliance Officer for Legal Practice (a position which is mandatory under applicable regulation) is also a key point of contact both internally and externally and has a regulatory duty to ensure that BLP takes all reasonable steps to comply with its statutory obligations.

NEXT STEPS

During the course of the year to 30 April 2018 we aim to:

• review the way in which we resource the management of our suppliers, including whether we centralise the function and appoint a procurement manager
• work towards embedding our commercial supplier on-boarding and contract management approach beyond our UK focused pilot phase and consider our international operations footprint
• publish communications across our BLP Group offices to raise awareness and educate our staff on modern slavery and human trafficking and the situations in which it may arise 
• continue to embed our processes and procedures and train relevant members of staff on the modern slavery and human trafficking elements of our commercial supplier on-boarding and contract management approach, including how to risk assess new suppliers, and current suppliers as their contracts come up for renewal, and, raising awareness about required measures when dealing with high risk suppliers   
• continue our dialogue with other international law firms about responsible and ethical business and supply chains with the aim of putting relevant peer learning into practice ourselves
• continue to contribute to the legal sector’s engagement with this issue by contributing to initiatives in this area and speaking at global business and human rights conferences and events 
• continue to provide advice to and work with our clients and other entities with whom we have business relationships about how to eradicate the risk of modern slavery and human trafficking in their businesses and supply chains. 

Key Performance Indicators will be:

• the number of core direct commercial suppliers we have engaged with on the issue of modern slavery
• training and education events and other awareness raising activities we have delivered or contributed to including, internally for BLP Group staff, for core suppliers, to clients and other entities with whom we maintain business relationships
• the number of high risk supplier contracts we have reviewed and/or updated with enhanced modern slavery provisions
• the number of reported concerns about modern slavery or human trafficking.

Date - 22.12.17

Lisa Mayhew
Designated member of Bryan Cave Leighton Paisner LLP

This statement is made by Berwin Leighton Paisner LLP (BLP) pursuant to section 54(1) of the Modern Slavery Act 2015 for the financial year ending 30 April 2016. It sets out the overall commitment and steps taken by BLP to ensure that slavery and human trafficking are not present in our business or direct supply chain.

BLP GROUP STRUCTURE

BLP is a law firm and limited liability partnership registered in England and Wales and is authorised and regulated by the Solicitors Regulation Authority (England and Wales).

The Berwin Leighton Paisner Group, which provides legal and related services to corporates and individuals had a consolidated global turnover of £254m for the financial year ending 30 April 2016 and employs over 1200 staff. For the purposes of this statement, “BLP Group”  includes Berwin Leighton Paisner LLP, Berwin Leighton Paisner (Services), Berwin Leighton Paisner (Germany) LLP, Berwin Leighton Paisner (HK) LLP in association with Haley Ho & Partners, Goltsblat BLP LLP and Berwin Leighton Paisner (Myanmar) Limited. None of the entities within the BLP Group (other than BLP) fall within the reporting obligation at this time.

We are committed to carrying on our business in a responsible and ethical manner that respects the rights and dignity of individuals and the communities where we operate and provide our services.  We have a zero tolerance policy to modern slavery and expect the same high standards and commitment from those we do business with.

OUR APPROACH

As an international law firm our operations and suppliers are based all over the world. To properly and transparently address the risks of modern slavery we have developed a systematic, risk based approach to identifying and assessing the risk of modern slavery within our business and direct supply chain. Our initial focus has been on our operations in England which is the location of our largest office with the greatest number of staff and the significant proportion of our business and turnover. We have started this process by reviewing our core legal services business and direct supply chain.

In the last financial year ending 30 April 2016 we have:

• established a dedicated project team to review procurement/external supplier management generally. Modern slavery and human trafficking forms a fundamental part of that remit and we are committed to working with suppliers to prevent slavery and human trafficking within their businesses and, specifically, where that is relevant to our business relationship with them. The team consists of representatives from our business services teams which has increased awareness of the risk of modern slavery and human trafficking across the firm and particularly amongst those staff dealing with our direct commercial external suppliers and key internal processes
• reviewed policies and procedures surrounding the engagement and management of external suppliers
• reviewed policies and procedures surrounding internal resourcing including employment and contracting practices
• commenced awareness raising and a dialogue about this topic with other law firms throughout the world who we work with on a regular basis (our Preferred Firm network) by addressing the risk of modern slavery and human trafficking at the network’s annual partner conference in March 2016. We will be continuing this work through further various initiatives.

To date we have not discovered issues of concern. Moving forward, we are committed to assessing any instances of non-compliance regarding modern slavery and human trafficking on a case by case basis. Our Whistleblowing Policy provides a channel of communication for staff who have concerns and we have a Complaints Handling Policy in place should clients wish to make a complaint. BLP’s Compliance Officer for Legal Practice (a position which is mandatory under applicable regulation) is also a key point of contact both internally and externally and has a regulatory duty to ensure that BLP takes all reasonable steps to comply with its statutory obligations.

NEXT STEPS

During the course of the year to 30 April 2017 we aim to:

• introduce new Ethical Business Principles
• introduce a new Supplier Code of Conduct
• risk assess new suppliers, and current suppliers as their contracts come up for renewal and raise awareness and engage with high risk suppliers
• seek to introduce contractual rights to request compliance-related information and the right to audit in our high risk supplier contracts together with warranties and the right to terminate for breach of our Supplier Code
• implement a modern slavery and human trafficking training programme for relevant members of staff and generally communicate and raise awareness about this topic throughout the firm. We will also continue our dialogue with our Preferred Firm network
• continue to provide advice to and work with our clients on how to eradicate the risk of modern slavery and human trafficking in their businesses and supply chains.

Key Performance Indicators will be:

• the number of high risk suppliers we have engaged with on the issue of modern slavery
• training and education events and other awareness raising activities we have delivered – internally, with material suppliers and to clients
• the number of high risk supplier contracts we have updated with additional modern slavery provisions.

Lisa Mayhew

Designated member of Bryan Cave Leighton Paisner LLP