Anti-Slavery and Human Trafficking Statement

Purpose of this Statement

This statement is made on behalf of Eversheds Sutherland (International) LLP and the employing entity of Eversheds Sutherland Legal Services Limited (together, "Eversheds Sutherland"), in accordance with Section 54(1) of the Modern Slavery Act 2015 ("the Act"). It covers the financial year of 1 May 2021 to 30 April 2022.

References in this statement to "we", "us" and "our" are to Eversheds Sutherland as defined above.

Overview of Eversheds Sutherland

Eversheds Sutherland is a global top 10 law practice with over 74 offices and related entities in 36 jurisdictions around the world. It operates as a limited liability partnership registered in England and Wales, owned by our partners, and employs over 4300 people worldwide.

We provide legal and commercial advice and solutions across a number of sectors to our international client base, which includes some of the world's largest multinationals. To find out more about our structure, what we do and our values, please visit the about us section of our website.

We are a professional services firm strictly regulated by professional regulatory bodies in the jurisdictions in which we operate, and our ongoing assessment is that we are at low risk of slavery or human trafficking occurring within our own business. This assessment is based on a number of factors, including that our business is primarily comprised of permanently employed, skilled staff, in a client-focused service sector, regulated within strict ethical frameworks. We consider there to be a greater risk of slavery or human trafficking occurring within our supply chains than within our own business.

Our Values and Business Initiatives

UN Global Compact

We are proud to be a participant in the UN Global Compact and to support the ten principles and the 17 Sustainable Development Goals of the Compact. The principles are embedded in our purpose of 'Helping our clients, our people and our communities to thrive' which is central to our firmwide strategy. Our 2022 Communication on Progress report sets out our commitment to being a responsible business and progress to date as well as our priorities for the year ahead. This report is available in our Corporate Responsibility page of our website.

People

We have an ongoing Wellbeing Programme which focuses on Mental Wellbeing, Physical Wellbeing and Working Well across all of our offices. The programme consists of: an Employee Assistance Programme with free guidance and support available 24/7 365 days a year to help with any personal issues such as stress, anxiety, medical concerns, financial concerns and family / relationship matters together with a Wellbeing and Ability Network to actively explore how the firm can support the wellbeing of our people.

During the reporting period we have:

launched our inaugural Global Inclusion Week to celebrate inclusion and difference across our firm
launched a set of wellbeing principles focused on being mindful towards one another at all times, balancing wellbeing and client service excellence and making adjustments to working practices to enhance the experience for all. We base these on the principles of the Mindful Business Charter

Community

Deeply ingrained in our culture is a recognition that we have a responsibility to use our skills and resources for the greater good of the communities in which we live and work. And, through our large-scale global network, we are well placed to address global challenges through local actions.

We partner with social mobility charities around the globe, supporting noteworthy non-profits and serving our communities' most vulnerable citizens. Our goal is to make a positive impact on all our communities through our pro bono, volunteer and charitable activities, using our talents and time for the benefit of others. For example, in July 2022 we were highly Commended at The Lawyer Awards for our pro bono work supporting 27 former members of the Afghan judiciary with their applications for UK visas. A team of over 50 lawyers continue to work on these cases, with many thousands of pro bono hours dedicated to the project.

Responsible Business Hub

In November 2021 we launched our Responsible Business Working Group and a Responsible Business Portal to deliver our strategy and to provide information on our achievements, new projects and initiatives that we are working on.

Our commitment to act in a professional, open and inclusive way includes our endorsement of the objectives of the Modern Slavery Act by the firm's Executive and the application of our modern slavery programme throughout the firm, as well as our continued effort to work with our suppliers to ensure the right processes, procedures and controls are in place as part of our supply chain.

Progress for the financial year ending 30 April 2022

Supplier Due Diligence

During the reporting period we have created a Modern Slavery risk assessment tool and a Modern Slavery due diligence programme to enable us to assess our suppliers for risks of any human rights violations within their operations and implement steps to manage those risks.

Supplier Risk Assessment

The Modern Slavery risk assessment tool categorises suppliers as either a low, medium or high risk for Modern Slavery, taking into account the sector, nature of the business and its country of operation.

Supplier Due Diligence

Depending on the outcome of the Modern Slavery risk assessment, our Modern Slavery due diligence programme sets out the steps which are required to be taken to manage the risk of any human rights violations within the supplier’s business.

The due diligence steps include (depending on the level of risk):

checking the supplier’s Modern Slavery statement
checking any of the supplier’s published policies and procedures
checking for any adverse media regarding any human rights concerns for that supplier
asking the supplier to complete a modern slavery declaration

These due diligence steps are undertaken both when the supplier is being onboarded (if their annual spend is over £10k) and annually thereafter.

Our standard supplier contracts also include specific obligations on modern slavery. Any breaches identified may result in us terminating our arrangements with the supplier.

Supplier Due Diligence during the Reporting Period

During the reporting period we used our Modern Slavery risk assessment tool to risk assess all our existing Tier 1 suppliers with an annual spend of over £50k. Once risk assessed, we completed the required due diligence steps for these suppliers as set out in our Modern Slavery due diligence programme. The quality and transparency of the responses to our Modern Slavery declaration have been assessed and we have engaged with, and fed back, to suppliers where needed.

Out of over 800 suppliers, 19 suppliers were assessed as being potentially medium risk and only 4 suppliers were assessed as being potentially high risk of Modern Slavery, primarily due to the country of operation.

Having completed the due diligence for these suppliers, we are satisfied they are taking appropriate action to manage any risk.

We have not identified any occurrences of modern slavery in our supply chain during this reporting period.

Policies

We have operational policies and procedures which are relevant to our approach to Modern Slavery and these are subject to continuous review and development. These include our:

Anti-Slavery and Human Trafficking Policy
Purchasing Policies and Procedures
Equality and Diversity Policy
Health and Safety Policy Statement
Whistleblowing Policy
Supplier Code of Conduct
Supplier Annual Declaration
More Detailed Supplier Annual Declaration for suppliers who are assessed as being at high risk of Modern Slavery due to their sector or country of operation

Training

Firmwide Mandatory Training

During the reporting period we prepared and launched an updated mandatory firmwide training module on Modern Slavery. The training covers an update on Modern Slavery legislation, our firmwide policies and procedures, awareness of our new Modern Slavery risk assessment programme for suppliers and sets out the red flags to look for in the work we undertake for clients.

The training is mandatory for all staff and all new starters as part of their induction training. We monitor the completion of this training module, during the reporting period the completion rate of this module for all new starters was 94%.

Supplier Training

In addition to the firmwide training, we recorded a podcast for our suppliers to train them on Modern Slavery. The training was aimed at improving our suppliers’ knowledge and understanding of what Modern Slavery is, the impact it can have, how to recognise any red flags and what the supplier's obligations are under our Supplier Code of Conduct, including how to report any concerns.

This training was sent to all of our Tier 1 suppliers who were assessed as medium risk or high risk for Modern Slavery as well as to a number of Tier 1 suppliers who were assessed as low risk.

Continuous focus on preventing slavery and trafficking

We continue to focus on improving our methods of preventing slavery and trafficking.

Some of the key steps we will be focussing on in the financial year to 31 April 2023 are set out below:

In the coming year we will be integrating our Modern Slavery risk assessment tool and our Modern Slavery due diligence programme into the firm’s new Supplier Relationship Management platform to enable newly onboarded suppliers to be assessed and any risks mitigated before the supplier is onboarded and ensure ongoing risk management and due diligence is undertaken for our existing suppliers
Following on from our recent supplier due diligence exercise we will undertake a further annual due diligence review of our high risk suppliers in line with our Supplier due diligence programme

Approval

This statement was approved by Keith Froud, Managing Partner International on 25 October 2022 on behalf of Eversheds Sutherland (International) LLP and Eversheds Sutherland Legal Services Limited.

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