At Brodies LLP we conduct our business with integrity, transparency and fairness. We are committed to the prevention of slavery and human trafficking in our business and in our supply chains. We procure goods and services in a sustainable and ethical manner in compliance with our values and relevant law and policy, including the Modern Slavery Act 2015.

We do not accept slavery or human trafficking in our business and we will not work with others on our supply chain 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, David Edwards, on 0131 656 0246.

Our business and supply chains

Brodies is a law firm headquartered in Scotland, regulated by the Law Society of Scotland and authorised and regulated by the Solicitors Regulation Authority (650996). We are a full service law firm offering legal advice to private and public sector clients both in the UK and internationally. Our core business areas are corporate and commercial; energy (renewables and oil & gas); property; litigation; banking and financial services; employment, pensions and benefits, and trust and tax.

We are a limited liability partnership registered in Scotland and we have offices in Aberdeen, Edinburgh, Glasgow, Dingwall and Brussels. Further information about our business can be found at: www.brodies.com/about.

Our supply chains include providers of services to our clients, and providers of goods and services to our firm. For example, we engage advocates, medical experts and property search companies on behalf of our clients and officers of the courts to serve official documents. Goods and services provided to the firm include banking services, stationery supplies, building management services for our offices, taxis, cleaning services, IT hardware and IT services.

Compliance

In relation to the financial year ending 30 April 2019 we have:

  • reviewed our compliance approach in line with the  2017 UK Government guidance on Transparency in Supply Chains, the 2019 UK Government guidance on modern slavery statements and the Scottish Government’s Slavery and Human Trafficking Guidance for Businesses in Scotland
  • conducted a slavery and human trafficking risk assessment of our business and our supply chains, as explained below
  • issued a slavery and human trafficking risk questionnaire to selected suppliers
  • reviewed and updated our supplier take-on processes to ensure our slavery and human trafficking risk questionnaire is issued where appropriate to new or prospective suppliers
  • held discussions within the firm to ensure compliance
  • reviewed our Anti-slavery Policy, which identifies the firm's Finance Director, David Edwards, as the Anti-slavery Compliance Officer with overall responsibility for implementing this Policy
  • arranged for colleagues with direct responsibilities for engaging with suppliers to undertake a bespoke anti-slavery and human trafficking training module
  • reviewed the Key Performance indicators against which to assess our progress on slavery and human trafficking issues.

Our Anti-slavery Policy documents our commitment to conducting our business with integrity, transparency and fairness and the steps we take to ensure that slavery and human trafficking is not present in our business or in our supply chains. This Policy applies to our partners, all of our 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 with examples of unusual behaviour displayed by workers which may be indicative of someone experiencing slavery or human trafficking. It makes it clear that Brodies will support anyone who raises a genuine concern in good faith.

Our Anti-slavery Policy builds on Brodies' existing policies covering Procurement, Equality, Diversity, Dignity at Work, Grievances, and our Employee Handbook as well as other internal training we provide.

Due diligence in our supply chains

We have reviewed and will continue to review our central list of suppliers. We have conducted a risk assessment of our supply chains based on annual spend, invoice frequency and a combination of these factors. Following this, we contacted a number of suppliers and asked them to complete our slavery and human trafficking risk questionnaire. 

That questionnaire communicates our commitment to complying with the requirements of the Modern Slavery Act 2015 and seeks information from them on, amongst other things, the nature of the goods or services they supply to us, and their anti-slavery policies and procedures.

Training

All members of staff are required to certify that they have read and understood our Anti-slavery Policy. A process is in place to monitor and enforce this requirement. This Policy is available to access on our intranet system and is also accessible at the link noted above. 

We have also arranged for colleagues with direct responsibilities for engaging with suppliers to undertake a bespoke anti-slavery and human trafficking training module.

Key Performance Indicators

We 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:

  • number of staff having confirmed that they have read and understood Brodies' Anti-slavery Policy
  • nature of and number of Anti-slavery Policy breaches reported to the Anti-slavery Compliance Officer 
  • number of Policy breaches assessed within a reasonable time of being reported and further investigations concluded as soon as possible thereafter
  • frequency and nature of follow-up communications, as appropriate, with relevant suppliers, or potential suppliers, in relation to our slavery and human trafficking risk questionnaire or supplier take-on process. 

We will continue to monitor the effectiveness of our compliance regime and take necessary steps to address any instances of slavery and human trafficking. 

We understand that an Anti-slavery Policy and supplier due diligence questionnaire will not themselves be sufficient to prevent slavery and human trafficking. We recognise the importance of developing a culture within the firm which does not tolerate slavery or human trafficking and is not complacent about the associated risks. Through our good business practices and Human Resources policies, including our adoption of the Scottish Business Pledge, we believe that Brodies has established such a culture. Brodies is committed to fostering this culture across the firm through training, education and awareness initiatives. 

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Brodies LLP slavery and human trafficking statement for the financial year ending 30 April 2019. This statement was approved by the Brodies LLP members on 3 December 2019.