At Brodies we conduct our business with integrity, transparency and fairness. We are committed to the prevention of slavery and human trafficking both in our business and in our supply chains as part of maintaining our reputation and the confidence of our clients and business partners. We undertake to procure goods and services in a sustainable and ethical manner in compliance with our values, relevant law and policy and the Modern Slavery Act 2015.
We do not accept slavery or human trafficking in our business and we will not work with others who do not share our commitment to preventing slavery and human trafficking. If you have any concerns or suspicions we should know about then please contact our Anti-slavery Compliance Officer on 0131 228 3777.
Our business and supply chains
Brodies is a Scottish law firm offering legal advice of the highest quality to private and public sector clients in core areas such as mergers & acquisitions, business disputes, commercial property, banking & financial services, employment, pensions & benefits and trust & tax. Our clients include big companies, small and medium sized enterprises, entrepreneurs, business people and individuals from all backgrounds who are active in almost every sector of the Scottish economy.
We are headquartered in Scotland and have offices in Aberdeen, Edinburgh, Glasgow and Brussels. Further information about our business can be found at: www.brodies.com/about.
Our supply chains include providers of client services and goods and services to our firm. For example, we engage sheriff officers, medical experts and property search companies on behalf of our clients. Goods and services provided to the firm include stationery supplies, taxis, cleaning services and IT services.
Since the Modern Slavery Act 2015 ("MSA 2015") came into force, we have built on our existing compliance framework by:
- consulting with our Public Law & Regulatory team on our compliance approach
- conducting a risk assessment of our business and our supply chains
- holding discussions within the firm to ensure compliance
- producing a specific Anti-slavery Policy, to be approved by the Risk Management Committee identifying the firm's Finance Director, David Edwards, as the Anti-slavery Compliance Officer with overall responsibility for implementing this policy
- identifying Key Performance indicators against which to assess our progress on slavery and human trafficking issues
Our Anti-slavery Policy reflects our commitment to conducting our business with integrity, transparency and fairness and to ensuring that slavery and human trafficking is not prevalent in our supply chains. The policy applies to all staff (both lawyers and support staff) and to our suppliers, including those who work for or on our behalf in any capacity.
The firm's Anti-slavery Policy includes guidance to our staff with examples of unusual behaviour displayed by workers which may be indicative of someone experiencing slavery or human trafficking. It also makes it clear that Brodies will support anyone who raises a genuine concern in good faith, even in circumstances where it transpires that those concerns are mistaken.
Our Anti-slavery Policy builds on Brodies' existing policies covering Procurement, Equality, Diversity, Dignity at Work, Grievances, the Employee Handbook and Training.
Due diligence in our supply chains
We have conducted a risk assessment of our supply chains based on annual spend, invoice frequency and a combination of these factors. We have also reviewed our supplier list to sense-check the results. We will shortly be writing to the suppliers we have identified to communicate to them our commitment to complying with the requirements of the MSA 2015 and our responsibility to ensure, as far as possible, that slavery and human trafficking is not occurring in any part of our supply chains. The letter will ask these suppliers to confirm the steps they have taken both internally and in their supply chains to ensure that slavery and human trafficking is not occurring, It will enclose a copy of our Anti-slavery Policy and provide a web-link to this statement.
All members of staff will be required to certify that they have read and understood our Anti-slavery Policy. After a period of two weeks, staff will be unable to use the firm's computers until they have confirmed that they have read and understood the policy. In addition, tailored training is provided to those staff within our firm who have responsibility for managing supplier contracts and for making purchasing decisions.
We will work with our suppliers where slavery and human trafficking issues arise in their businesses or their supply chains. We will also be updating our supplier terms and conditions and providing new suppliers with our Anti-slavery Policy.
Key Performance Indicators
We will use the following Key Performance Indicators (KPls) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
- All staff have confirmed that they have read and understood Brodies' Anti-slavery Policy
- Any policy breaches are reported to the Anti-slavery Compliance Officer within a reasonable time of occurring
- Any policy breaches are assessed within a reasonable time of being reported and further investigations concluded as soon as possible thereafter
Over the course of the next year, we intend to take the following further steps to combat slavery and human trafficking:
- Include specific slavery and human trafficking obligations in supplier terms and conditions
- Ensure that material new firm suppliers receive a copy of our Anti-slavery Policy
- Review and, as appropriate, update our supplier take-on processes
We will continue to monitor the effectiveness of our compliance regime and take necessary steps to address any instances of slavery and human trafficking.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 30 April 2016.