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 2022 to 30 April 2023 (‘the Reporting Period’).

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 75 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 4,400 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 chain than within our own business.

We are committed to ensuring that as a business we take steps to minimise the risk of modern slavery in our business or supply chains, and to acting ethically and with integrity in all our relationships.

Our Values and Business Initiatives

UN Global Compact

We are proud to be a participant in the UN Global Compact. This is a global initiative that calls upon companies to align their strategies and operations with universal principles on human rights, environment and anti-corruption, and take actions that advance societal goals. 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 2023 Responsible Business Report sets out our commitment to being a responsible business and our progress to date, as well as our priorities for the year ahead. This report is available in our Responsible Business Page on our global website.

People

We are an Accredited Living Wage Employer, meaning that we have committed to pay all of our employees a fair living wage.

We have an ongoing Wellbeing Programme which focuses on Mental Wellbeing, Physical Wellbeing and Supporting Performance for all our employees across all of our offices. The programme includes access to our 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.

During the Reporting Period we have marked Mental Health Awareness week and Global Mental Health Day with events highlighting practical tools and techniques to enhance wellbeing and support performance.

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. 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. Some of the key projects we have worked on during this reporting period are:-

Afghan Pro Bono Initiative : We are part of a collaboration of 14 UK-based firms working with NGOs Safe Passage and Refugee Legal Support, set up to assist Afghan refugees with regard to resettlement and family reunion applications in the UK.
Ukraine Advice Project: We have collaborated with two other firms and immigration specialists to deliver an immigration signposting and triage service for displaced Ukrainians and their families, to help them navigate the various immigration options available to them within the UK. Over 100 UK volunteers have been involved in this project, which has supported over 5,000 individuals to date.
KIND UK: We work with Kind UK via the Central England Law Centre and JustRight Scotland to provide legal support to stateless children in the UK. Pro bono volunteers support families of children seeking British citizenship with their applications to the Home Office, including preparing supporting evidence. We have had a success rate of 100% to date for our clients.
Rule 39 Initiative: We collaborate with NGO Italian Coalition for Civil Liberties and Rights (CILD) and 7 other international law firms, supporting migrants/refugees in continental Europe by making applications to the European Court of Human Rights for emergency protection against human rights violations by particular states. Volunteers from our offices in Amman, France, Germany, Luxembourg, Netherlands and the UK work on these cases.
Windrush Compensation Scheme: We have partnered with United Legal Access to provide assistance to individuals making an application for compensation under the Windrush Compensation Scheme to assist people who have arrived in the UK but do not have the correct documentation to confirm their immigration status. Our role is to make sure the individual has sufficient information to be able to make a successful claim under the scheme, to assist them with compiling evidence and the completion of the application form to enable the individuals to provide their right to work and live in the UK.
Manuel Bravo Project: We work with Leeds-based not-for profit Manuel Bravo Project to provide free legal assistance to asylum seekers with regards to First Tier Tribunal appeals and fresh claims. We also provide legal assistance with settlement protection applications for refugees.
International Rescue Committee: In the reporting period, we announced a five-year global charity and pro bono partnership with IRC and provide the organisation with pro bono support on various issues on a global basis, as well as providing significant financial support. The mission of the IRC is to help people whose lives and livelihoods are shattered by conflict and disaster, including the climate crisis, to survive, recover and gain control over their future.

Clients

We are proud to be a founding member of the Business and Human Rights Lawyers Association , which is a global platform that inspires and advances business and human rights leadership, learning and collaboration amongst commercial law firms and business lawyers around the world. Being part of this association highlights our commitment to ensure we provide topflight legal advice to companies on the crucial matters of human rights.

During the Reporting Period we have created an internal Supply Chain Working Group which consists of a global network of our lawyers all of whom advise clients on supply chain issues (including human rights) issues in their different practice areas. The group work collaboratively together and meet every 2 months with a focus on sharing knowledge and insights to enable them to provide the best advice to our clients on developing areas such as supply chain due diligence and supply chain reporting.

We have mandatory training and guidance on Modern Slavery for all our staff which includes information on the work types and red flags to look for which may indicate a risk of modern slavery in the matters or transactions we are advising on. Our subject matter experts across the different practice groups can then, if so needed, help advise our clients on how best to respond to any issues identified.

Progress for the financial year ending 30 April 2023

Supplier Due Diligence

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

Our supply chain is built around supporting our core legal practice and maintaining the firms business services, technology and infrastructure as such, our suppliers fall into two main categories:-

Professional Services Suppliers who are mainly used by the firm’s lawyers and practice groups in the provision of its legal services, these suppliers include for example other law firms, barristers, accountants, tax advisors, insurance providers and external training providers; and
Business Services Suppliers who are used by our business services teams to ensure the firm can maintain its normal day-to-day operations, such as catering, security, print and document services and its technology and infrastructure, such as IT systems and software.

We consider that our Professional Services Suppliers present a low risk of modern slavery and human trafficking as they consist of skilled staff who work within strict regulatory frameworks. Given this, we have not individually risk assessed each and every Professional Services Supplier. We consider there is a greater risk of slavery or human trafficking occurring within our Business Services Suppliers.

In 2022 we used our Modern Slavery risk assessment to risk assess our existing Business Services Suppliers with an annual spend of over £50k. We assessed over 800 suppliers of which 19 were assessed as being medium risk and only 4 were assessed as potentially high risk, primarily due to the country of operation. Having completed the due diligence for these higher risk suppliers, we are satisfied they are taking appropriate action to mitigate any risk.

Supplier Due Diligence during the Reporting Period

During the Reporting Period, we have implemented a new Supplier Relationship Management platform. This platform enables us to assess the firm’s new suppliers for risks across a number of key areas such as Health & Safety, Sustainability, Diversity and Inclusion and Corporate Responsibility, before they are onboarded.

During the Reporting Period we have integrated our Modern Slavery risk assessment and due diligence process into our new Supplier Relationship Management platform and through this platform we have fully risk assessed over 170 new Business Services Suppliers. We have undertaken the required due diligence on these suppliers in line with our Modern Slavery Due Diligence programme. Out of the 170 assessed, 9 were deemed a medium risk of Modern Slavery and 1 was assessed as a higher risk, due to the country of operation. As part of the due diligence process 95% of these suppliers have agreed to adhere to our Modern Slavery Code of Conduct and have signed our Modern Slavery Declaration before they were onboarded. In signing our Modern Slavery Annual Declaration these supplier have committed to adhere to our Modern Slavery Code of Conduct which sets the minimum standards we expect from our suppliers. The remaining 5% have provided us with their own Code of Conduct which aligns with the requirements set out in our Modern Slavery Code of Conduct.

For the 4 existing Business Services Suppliers we assessed as being high risk and the 1 newly onboarded high risk supplier, we have undertaken our annual due diligence in line with our Supplier due diligence programme, (which included one face to face audit) and remain satisfied that these suppliers are taking appropriate action to mitigate any risk.

During the Reporting Period we have not received any modern slavery-related complaints either directly or through our whistleblowing channel.

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
Modern Slavery Supplier Code of Conduct and Annual Declaration
Global Ethical Code of Conduct
Whistleblowing Policy
Purchasing Policies and Procedures
Equality and Diversity Policy
Health and Safety Policy Statement

Training

Firmwide Mandatory Training

We have an existing and ongoing firmwide training module on Modern Slavery which is mandatory for all of our staff and new starters. The training covers an overview of the 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.

We monitor the completion of this training module and during the reporting period the completion rate of this module for all new starters was 97%.

Supplier Training

In addition to the firmwide training, we continue to send our suppliers our Modern Slavery Supplier Training which we have recorded as a podcast. This podcast is 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.

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 focusing on in the financial year to 31 April 2024 are set out below:

We will widen the scope of our new Supplier Relationship Management platform to enable newly onboarded suppliers for our Non-UK offices to be assessed and any risks mitigated before the supplier is onboarded.
We will refresh and re-circulate our mandatory firmwide training on Modern Slavery to ensure all of our staff remain aware of the risk of Modern Slavery both within our business, our supply chains and in the work we do for our clients.
We will refresh and update our Supplier Training Podcast to ensure we improve our suppliers’ knowledge and understanding of what Modern Slavery is, the impact it can have, how to recognise and report any concerns they have to us.
We will update our Whistleblowing policy and firmwide process to ensure we are doing everything we can to actively encourage a ‘speak up culture’ both for our staff and also third parties to report any concerns to us (including any Modern Slavery concerns) as soon as possible.
We will continue to undertake our annual due diligence review of our higher risk suppliers in line with our supplier due diligence programme.

Approval

This statement was approved by Keith Froud, Managing Partner International on 13 October 2023 on behalf of Eversheds Sutherland (International) LLP and Eversheds Sutherland Legal Services Limited.

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