Modern Slavery and Human Trafficking Statement 2022
This statement is made by Kennedys Law LLP (‘Kennedys’) under section 54 of the UK Modern Slavery Act 2015 for the financial year ending 30 April 2022.
According to the charity Anti-Slavery International at least 24.9 million people are thought to be in trapped in forced labour worldwide. Of them, 16 million are exploited in the private sector, linked to the supply chains of the international businesses supplying our goods and services. Slavery exists in all stages of the supply chain, from the picking of raw materials, to the manufacturing of goods and at later stages of shipping and delivery to consumers.
Modern Slavery can include:
Slavery - Exercising powers of ownership over a person
Servitude - The obligation to provide services is imposed by the use of coercion
Forced or compulsory labour - Work or services are exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily
Human trafficking - Arranging or facilitating the travel of another person with a view to their exploitation
THE FIRM AND STRUCTURE
Kennedys is a limited liability partnership registered in England and Wales with a registered number OC353214 and registered at 25 Fenchurch Avenue, London, EC3M 5AD. We are a global law firm with expertise in dispute resolution and advisory services, especially in defending insurance and liability claims. We have over 2300 people across 23 countries and operate from 43 offices and 28 associations or co-operations globally. In the last financial year our global turnover was £286m. Further detail about the nature of our business can be found on the firm’s website.
A high proportion of the firm’s suppliers are professional advisers and experts who are engaged on client matters and the remainder provide goods and services to the business including the firm’s accountants, banks, brokers and insurers, furniture suppliers, office supply companies, office cleaners, caterers, vending machine suppliers, electrical and building contractors, archive facilities, phone providers, suppliers of IT equipment, software and licences, software developers, website designers, couriers, travel advisers, recruitment agencies, trainers, seminar providers, publishers of hard copy and digital materials, motor fleet providers, event managers and photographers.
UN GLOBAL COMPACT
Since the firm’s initial commitment to integrate the Ten Principles of the United Nations Global Compact in June 2020 into core business practices, Kennedys re-affirms its commitment to the United Nations Global every year by submitting our annual Communication on Progress which provides evidence of our public declaration that the firm is committed to implementing responsible business practices in the areas of human rights, labour, environment and anti-corruption. In 2022, we will continue to incorporate the Ten Principles of the UN Global Compact into business and management systems and also focusing on the sustainable practices of the firm’s supply chain. We have agreed commitments and targets aligned with the UN Sustainable Development Goals, with Goal 10 (Reduced Inequalities) being particularly relevant to modern slavery. Kennedys’ latest Communication on Progress report can be found here.
PROGRESS SINCE 2021
Over the course of the last 12 months the firm has established a process for verifying that key suppliers or suppliers in high risk sectors or countries comply with the firm’s Supplier Code of Conduct. These audits cover all of the criteria set out in the Code including suppliers’ compliance with the Modern Slavery Act 2015 in their own working practices and those of their own supply chain. The results from the last 12 months show that all of the suppliers that were audited provided evidence within the firm’s deadline, complied with the Supplier Code of Conduct and completed the necessary training; importantly, no incidents of Modern Slavery were reported, either within the firm or by our suppliers whether by whistle-blowers or by others.
Kennedys is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain.
Our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains involve (where possible) building long-standing relationships with suppliers and contractors who understand and are clear about the expected behaviours to enable the firm to:
- Establish, monitor and assess areas of potential risk in our business and supply chains;
- Reduce the risk of modern slavery and human trafficking occurring in our business and supply chains;
- Provide adequate protection for whistle-blowers.
We have introduced a Supplier Code of Conduct that clearly sets out the firm’s expectations about modern slavery and other important compliance issues including labour and human rights, the environment, business ethics and sustainable procurement.
On an annual basis we carry out due diligence audits on a risk-based approach to verify the extent of compliance by all key suppliers and any potentially high risk suppliers. We measure their performance against key performance indicators including the percentage of key suppliers who complete the due diligence audits, the percentage of audits that are fully compliant, the completion of training and the number of notified incidents. Non-compliance by a supplier will be a factor in any subsequent decision about whether they are retained or are invited to re-tender, based upon our Sustainable Procurement Policy by which the firm commits to favour suppliers who:
- Publicly demonstrate their support for the United Nations Sustainable Development Goals;
- Take action to reduce their direct and indirect environmental impact;
- Ensure that slavery and human trafficking is not taking place in their supply chain or any part of their business;
- Comply with International Labour Organisation principles in respect to human rights and conditions of employment;
- Have a diverse and inclusive management structure, workforce, and supply chain;
- Provide a fair wage to employees and contractors.
We have assessed the risk of modern slavery and human trafficking to be low across the firm due to the geographical location of our offices and the mainly advisory nature of our business.
The firm’s policy is to:
- maintain clear policies and procedures preventing exploitation and human trafficking, and protecting our workforce and reputation;
- be clear about our recruitment policy;
- check our supply chains;
- lead by example by making appropriate checks on all employees, recruitment agencies and suppliers to ensure we know who is working for us;
- ensure we have in place an open and transparent grievance process for all staff;
- seek to raise awareness so that our colleagues know what we are doing to promote their welfare;
- make a clear annual statement setting out the steps we have taken to ensure slavery and human trafficking is not taking place in our supply chains and to demonstrate that we take our responsibilities to our employees and our clients seriously.
All employees and partners are required to read and comply with our Modern Slavery Policy above and to undertake refresher training at least every 2 years, which helps employees and partners to understand the implications of slavery, identify risk factors and assist with implementing the policy effectively.
Over the next 12 months we will:
- Extend our due diligence audits on a risk-based approach to verify the extent of compliance by all key suppliers and any potentially high risk suppliers globally.
- Regularly monitor the key performance indicators relating to the percentage of key suppliers who complete the due diligence audits, the percentage of audits that are fully compliant, the completion of training and the number of notified incidents.
Continually review our procurement procedures and processes to ensure that our obligations under the Modern Slavery Act 2015 are passed through to our supply chain.
Global Risk Director
Partner for Kennedys
21 September 2022