Potter Clarkson LLP (“Potter Clarkson”) is committed to ensuring that there is no slavery or human trafficking in any part of our business or in our supply chains. This statement sets out our current risk analysis and the steps that Potter Clarkson has taken to deliver on our commitment and on our obligations under the Modern Slavery Act 2015 (“the Act”).
Potter Clarkson is a limited liability partnership registered in England and Wales (registered number OC315197) and is authorised and regulated by IPReg (registered number 464604) to provide legal services. Potter Clarkson has 42 partners and a total headcount, including consultants, of 214 both nationwide and in mainland Europe. In the UK, it operates from offices in Nottingham and London.
OUR RISK ANALYSIS
Potter Clarkson’s financial year is the calendar year. This firm became subject to the statutory obligations under the Act when its turnover exceeded £36m for the first time in 2018. Prior to this, the firm had been mindful of the importance of the Act and had voluntarily entered into the spirit of it. Because of the due diligence and analysis of the Potter Clarkson business and our supply chains carried out over many years, we consider that Potter Clarkson is currently at a low risk of slavery and human trafficking in both the context of our own business and our supply chains. We are proud that our position did not change when we became subject to the Act.
OUR POLICIES AND PROCEDURES IN RELATION TO SLAVERY AND HUMAN TRAFFICKING
With regards to our employees, we presently do not have any migrant labour. All employees are paid at least the living wage, usually well above it, except any apprentices who are paid the applicable statutory rate. Indeed, we have insisted, for example, that the Agencies that undertakes our office cleaning in Nottingham and London are contractually obliged to pay its cleaners the living wage which is of course effectively funded by us.
The standard terms and conditions of employment for our staff provide for the freedom of the employee to terminate his or her employment at any time, and state that any overtime is by agreement between Potter Clarkson and the employee.
We normally carry out an annual employee survey to seek opinions, views and suggestions on a whole range of employment and office issues. It can be answered anonymously if the employee wishes. These started in the Spring of 2014, and some of the results are now used as part of the metrics for the firm’s Business Plan. Our last survey, in April 2019, demonstrated that our employees continue to have high levels of engagement, with especial appreciation for the efforts of the firm to enhance work/life balance and provide generous benefits. The survey for 2020 has been delayed by reason of COVID-19 but is expected to take place in the Autumn.
Potter Clarkson also has the following policies published on our Intranet (which is accessible to all employees):
- Whistleblowing policy: protecting whistle-blowers through our confidential reporting process
- Harassment policy: prohibiting harassment and intimidation
- Disciplinary policy: prohibiting any threat of violence
Training on slavery and human trafficking risks and the requirements of the Act is available to partners and staff.
With regard to our supply chain, Potter Clarkson’s purchasing policy provides that anyone responsible for purchasing services from suppliers is expected to observe the highest standards of honesty and fairness and work in a manner which ensures full accountability, consistent with the firm’s core values.
We are committed to acting ethically, with integrity and transparency, and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within our supply chain. A supply chain compliance programme is in place. This programme is designed to:
- identify and assess the potential risk areas in our supply chains; and
- require that all relevant suppliers comply with the Act
- and are transparent, accountable, auditable and free from ethical ambiguities.
In any event, we operate and maintain a preferred supplier list. We have conducted due diligence on those suppliers we perceive to be high risk or vulnerable, in alignment with the Chartered Institute of Purchasing & Supply guidance. This approach is also undertaken on any new supplier before allowing them to become a preferred supplier (including due diligence relating to compliance with the Act). With regard to existing suppliers, we were satisfied with the outcome of our due diligence. If we had been dissatisfied with any supplier, we would have looked to disengage ourselves from them when any contract permitted.
We expect all our delivery partners, organisations within our frameworks and other companies we engage with to ensure their goods, materials and labour-related supply chains are free from any form of modern slavery. As a company only recently subject to the Act, our terms and conditions of purchase and framework supply agreements are being amended, when they can be, as appropriate and as necessary to include appropriate contractual provisions to ensure that all relevant suppliers are contractually committed to seeking to avoid the use of slave labour and trafficked labour.
As part of our on-going risk mitigation, we will:
- act promptly where a compliance breach has been identified or flagged; and
- continue to feed-back lessons learnt into the compliance risk management process.
OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
The above procedures are designed to reduce the risk of slavery and human trafficking occurring in our business and supply chains, and to enable us to monitor potential risk areas in our business and supply chains.
As outlined at the outset of this statement, our current assessment is that Potter Clarkson is at low risk of slavery and human trafficking occurring in our business and our supply chains. We will regularly review measurement criteria to assess our effectiveness in the future.
We will look to enhance as necessary our due diligence on our suppliers through a due diligence questionnaire to our suppliers where we consider that the risk profile merits a higher level of due diligence.
This statement is made pursuant to section 54(1) of the Act and constitutes Potter Clarkson’s slavery and human trafficking statement for the financial year ending 31 December 2020.