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 40 partners and a total headcount, including consultants, of 191 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. Our unaudited 2018 accounts indicate that this firm is now subject to the statutory obligations under the Act. Despite this, the firm has been mindful of the importance of the Act and has, in the past, 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 to date, 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 does not change now that we are 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 Agency that undertakes our office cleaning in Nottingham is contractually obliged to pay its cleaners the living wage.
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 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 2014 with 2019’s survey being open for completion by Survey Monkey between 18 and 29 March. Our last survey, in April 2018, 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.
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.
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. Now that we are very recently subject to the Act, it is our intention to put in place a supply chain compliance programme. This programme will be designed to:
- identify and assess the potential risk areas in our supply chains; and
- require that all of our 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 will now conduct due diligence on suppliers we perceive to be high risk or vulnerable, in alignment with the Chartered Institute of Purchasing & Supply guidance. This will of course be 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 shall also undertake this exercise and, if dissatisfied with the outcome, we will look to disengage ourselves from them when any contract permits (although from previous voluntary enquiry, we do not anticipate any issues).
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 newly subject to the Act, our terms and conditions of purchase and framework supply agreements are being amended 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 be looking to develop measurement criteria to assess our effectiveness in the future.
We will look to enhance our voluntary 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 2019.