This statement is made on behalf of Norton Rose Fulbright LLP and Norton Roses Fulbright Services (the Firm) pursuant to section 54 of the Modern Slavery Act 2015 (the Act) and constitutes our slavery and human trafficking statement for the financial year ending 30 April 2016.
Wherever we are, we operate in accordance with our Business Principles of quality, unity and integrity. These Business Principles guide our activities and staff across our offices. They describe our culture, the way we work and what we stand for. We value our people and promote a culture of respect for the individual.
This statement illustrates how we apply our Business Principles in practice and represents our public commitment to challenge and confront the use of forced, compulsory, trafficked or child labour within our own organisation, our supply chains and our value chain.
Our structure, business and supply chains
The Firm has offices in Abu Dhabi, Almaty, Amsterdam, Athens, Bahrain, Bangkok, Beijing, Brussels, Casablanca, Dubai, Frankfurt, Hamburg, Hong Kong, London, Luxembourg, Milan, Monaco, Moscow, Munich, Paris, Piraeus, Rio de Janeiro, Shanghai, Singapore, Tokyo and Warsaw.
The Firm provides legal services to business enterprises, governments and other public sector organisations. We are focused on key industry sectors: financial institutions; energy; infrastructure, mining and commodities; transport; technology and innovation; and life sciences and healthcare.
The Firm’s suppliers include suppliers of IT and communications, property; office cleaning and other facilities management services; transport such as airlines and couriers; marketing such as merchandise suppliers and conference providers; office equipment and supplies; and professional services such as auditors, legal counsel, banks, insurers and recruitment agencies. The Firm also has some suppliers that provide legal services which are used in the provision of services to our clients.
The Firm is working on the implementation of a comprehensive human rights policy. A working draft has been prepared and our Business and Human Rights Group is working with our General Counsel Office and our Compliance department to progress the policy with the intention of implementing the policy in 2017.
We have reviewed our Employee Handbook comprising all our employee-related policies. The following policies were amended to alert all our staff explicitly to modern slavery issues, the commitment of the Firm to combat modern slavery and mechanisms through which modern slavery issues can be addressed, if identified, in our organisation:
- Dignity at Work Policy; and
- Ethical Reporting Policy (known internally as ‘Report It’).
Our Ethical Reporting Policy is published on our intranet and enables any member of staff to report any known or suspected breach of our ethical standards including slavery, human trafficking, forced or child labour, as well as wider human rights-related issues. It guarantees that any issue can be raised in confidence and refers to examples of forced, compulsory or trafficked labour as instances which we expect to be reported.
Due diligence process and steps taken to assess and manage slavery and human trafficking risk
We have over 2,500 people (employees, partners and contractors) engaged in Norton Rose Fulbright LLP and we apply the highest possible standards in the recruitment and employment of our people.
As well as ensuring that the policies set out in the previous section are complied with, we ensure that:
- all legal obligations are complied with in the recruitment and on-boarding process with a particular focus on an individual’s right to work in the relevant country in which they will be engaged;
- we conduct an appropriate level of due diligence on our prospective employees prior to them joining the firm including a robust selection process and taking up employment references; and
- we recruit, promote and develop our people on the grounds of merit and capability alone and have a well-developed Diversity & Inclusion policy and plan to ensure we have a diverse workforce and an inclusive culture.
All staff are expected to comply with our Business Principles as well as any relevant laws and professional codes of conduct applicable to us. These ethical principles are enshrined in our employment contracts and supported by existing policies, as set out in our Employee Handbook.
In 2016 the Firm has concentrated on starting the due diligence process on our supply chains.
An impact assessment process has been carried out to date in accordance with the following methodology:
- the process started from identifying tier 1 suppliers and, where appropriate, owners of contractual relationships sought to establish the point of origin from which the products were made or services delivered;
- each contractual relationship was allocated a risk category representing an appropriate degree of modern slavery risk. The underlying risk level allocation methodology was based on key factors such as geographical location and the industry type relevant to the product or service being provided. The risk categories matrix was informed by independent studies and reports into the prevalence of modern slavery in monitored countries or sectors;
- high risk relationships were identified for further due diligence with the aim of better understanding our relationship with high risk suppliers and to establish what measures they have in place to combat modern slavery. Where necessary, suppliers were contacted with requests for further information to perform an enhanced due diligence. This process continues during this financial year 2016/2017;
- the methodology envisages escalation of any potential adverse human rights impacts to our General Counsel Office for further investigation; and
- our goal is to risk-assess new Firm supply contracts on the basis described above and a methodology for implementing standard contractual protections into low and moderate risk contracts and for addressing any high risk contracts has been put in place.
As at 30 April 2016 our due diligence process had not identified any specific adverse modern slavery impacts. Our Policy for Third Party Supply Contracts has been revised to include modern slavery screening methodology principles and a Supplier Charter has been introduced that positions our expectations of suppliers in the wider business ethics sense. Human rights form one set of principles the Firm expects our suppliers to adhere to.
As a provider of legal services we are required by applicable legislation and codes of conduct to take steps to identify our client and our scope of engagement. The overriding principle is that we will not act for clients in circumstances where it is illegal or inappropriate to do so. We require our partners to monitor their high risk files on a frequent basis and we require all legal staff to report known or suspected breaches of laws or ethical standards.
Through our advisory work and the sharing of best practices we are committed to supporting our clients’ respect for, and understanding of, human rights issues and impacts, including modern slavery.
In the past financial year our Business and Human Rights Group has worked closely with our corporate team to revise our client precedents, including contractual clauses for supply and outsourcing contracts, due diligence questionnaires for M&A transactions and checklists for listed companies publishing annual reports.
Training specifically addressing modern slavery issues has been delivered to clients at various events in London, including six-monthly Company Secretary Forum, the Outsourcing Day and the Employment breakfast briefing.
During our reporting year 2015/2016, we have strengthened, developed and, where necessary, established underlying principles, systems and processes in the above areas of business of the Firm which will be expanded and progressed in subsequent years. Tracking processes will be introduced in due course.
We recognise that the knowledge, responsibility and conduct of our staff plays an important role in mitigating the risk of slavery and human trafficking within our organisation. To help our employees identify and address modern slavery risk in our business, we offer targeted training:
- As a purchaser of services: A training module has been designed and the first phase delivered for the Firm’s procurement function including procurement professionals as well as other staff authorised to enter into contracts for the provision of goods and services, including senior Partners, providing detailed training on the new methodology introduced to cover the human rights aspect of contractual relationships with our suppliers.
- As a provider of services: The corporate, disputes, technology and outsourcing and real estate teams in London have already been trained on the application and impact of wider human rights issues in our advisory work as well as on the specific requirements of the Act and the issues it raises.
- With respect to mitigating specific modern slavery risks, a training module is being prepared which will form a part of our compliance structure and will be provided to all our fee-earners periodically.
We have a dedicated international Business and Human Rights Group which focuses on issues of business and human rights including modern slavery and human trafficking.
For Norton Rose Fulbright LLP
For Norton Rose Fulbright Services