Modern Slavery Act Statement 2022

This statement is made on behalf of Norton Rose Fulbright LLP and Norton Rose Fulbright Services (together, the Firm) pursuant to Section 54 of the Modern Slavery Act 2015. It constitutes the Firm’s slavery and human trafficking statement for the financial year ending 30 April 2022.

The Firm is committed to identifying and minimising the risks of modern slavery throughout its supply chain.

The Firm is also committed to operating in accordance with its Business Principles of Quality, Unity and Integrity. These Business Principles guide our staff and our activities. They describe our culture, the way we work and what we stand for. We value our people and maintain an environment where individuals feel safe and respected.

This statement illustrates how we apply our Business Principles in practice and reflects our continued public commitment to confronting 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 Amsterdam, Athens, Bangkok, Beijing, Brussels, Casablanca, Dubai, Frankfurt, Hamburg, Hong Kong, London, Luxembourg, Milan, Monaco, Munich, Newcastle, Paris, Piraeus, Shanghai, Singapore, Tokyo and Warsaw.

The Firm provides legal services to business enterprises, governments and other public sector organisations. We are focused on six key industry sectors: consumer markets, financial institutions, energy, infrastructure and resources, transport, technology, and life sciences and healthcare.

The Firm’s suppliers can be broadly categorised as follows:

Real Estate and related services: the Firm leases and occupies a number of offices across Europe, the Middle East and Asia, where maintenance, security, catering, cleaning and other services are required.
Professional Services: insurers, banks, accountants, auditors, translators, administrative services, marketing, legal counsel and recruitment agencies.
Travel: airlines, rail and taxi companies, travel agencies, hotels and other accommodation providers.
Technology: software and hardware retailers, consultants, maintenance companies and technology related service providers.

The Firm expects its suppliers to adhere to responsible human rights practices that are consistent with the Firm’s own principles.

Since June 2019, the Firm has incorporated its Additional Terms of Purchase for Goods and Services into contracts with suppliers. One of those additional terms requires suppliers to comply with the Firm’s Supplier Charter.

The Firm’s Supplier Charter and Additional Terms of Purchase for Goods and Services are published on the Firm’s website. Our Supplier Charter sets out our expectations of suppliers in the wider business ethics sense and is a key document in all new supplier relationships that the Firm forges.

Members of staff and management involved in the procurement of goods and services have been trained to identify and monitor potential human rights issues and to use appropriate governance channels and protections in high-risk situations. These governance processes are being utilised successfully and the Firm has put measures in place to monitor compliance.

Policies

Human Rights

Our Human Rights Policy is reviewed regularly and is supported by the provision of business and human rights (BHR) training to the Firm’s staff.

Our Human Rights Policy reinforces the Firm’s commitment to respecting internationally recognised human rights on multiple fronts, including as a provider of legal services, purchaser of goods and services, and as an employer. It also sets out our expectations for the conduct of our business partners.

BHR training of our staff comprises an eLearning module which covers the Firm’s BHR agenda and includes guidance on the main principles of the policy and its relevance to our staff, according to their specific functions. This training is mandatory for all staff of the Firm and is included as part of the induction programme for all new joiners.

Modern Slavery

Our Employee Handbook, which contains all of our employee related policies was reviewed and updated in 2021 to take account of modern slavery issues.

Our Ethical Reporting Policy is published on the Firm's intranet. It encourages members of staff to report known or suspected breaches of our ethical standards (including slavery, human trafficking, forced or child labour and broader humans rights related issues, amongst other things) and sets out procedures for doing so. It assures staff 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

Employment

The Firm applies the highest possible standards in the recruitment and employment of our people.

As well as ensuring that the policies set out in the Employee Handbook are complied with, we:

ensure that all applicable regulatory obligations are complied with in the recruitment and on-boarding process;
conduct an appropriate level of due diligence on our prospective employees prior to them joining the Firm, including a robust selection process and applicable background checks;
have a robust Diversity and Inclusion policy, which emphasises the Firm’s commitment to having a diverse workforce and an inclusive culture, including affirmative action around the development of individuals from BAME backgrounds who otherwise meet our criteria on merit and capability; and
continue to re-inforce the Firm’s Respect in the Workplace policy.

All staff are expected to comply with our Business Principles and any applicable laws and/or professional codes of conduct. These ethical principles are enshrined in our employment contracts and supported by the Firm’s policies, as set out in our Employee Handbook.

The Firm conforms to the London Living Wage for its London employees and complies with all regulatory requirements in the offices in which we operate.

Likewise, the Firm’s London suppliers are required to pay at least the London Living Wage to their employees.

Our Clients

As a provider of legal services, we are required to conduct due diligence on our clients and identify our scope of engagement in accordance with applicable legislation and professional codes of conduct. The overriding principle is that we will not act for clients in circumstances where it is illegal or inappropriate to do so. The Firm has robust internal and external reporting procedures to deal with instances where illegality is suspected during the course of a matter.

The Firm’s Human Rights Policy requires that we implement processes to assess potential human rights impacts as part of our client and matter intake processes. Our dedicated risk and compliance team members have been trained to consider the human rights record of, amongst other things, the client, counterparties and any relevant jurisdiction(s) during the client due diligence and matter opening processes. Clients and matters are monitored for such risks throughout the course of the client relationship or matter.

Our Partner Quarterly Return Questionnaire collates information on partners’ reflections on human rights issues in relation to all of their matters.

It is also the Firm’s practice to alert our clients to human rights issues which may arise in their transactions or commercial practices and work with them through these issues.

Through our advisory work and sharing of best practice, we are committed to supporting our clients’ respect for, and understanding of, human rights issues and impacts, including modern slavery.

Effectiveness Tracking

During 2021/2022, we achieved the following KPIs:

review of our Supplier Charter; and
provision of targeted training to our procurement team and other staff members involved in supply chain management.

Due to covid-19 restrictions and unanticipated geo-political issues, we were unable to complete a BHR due diligence review and risk assessment of one of the Firm’s non-UK offices as planned. That review will take place this year.

We continue to build on the Firm’s achievements with ongoing monitoring, assessments and improvements to ensure relevant and genuine commitment to BHR.

We shall report on our performance against the following KPIs in our 2023 Modern Slavery Act statement:

complete a comprehensive BHR due diligence review and risk assessment in one of the Firm’s non-UK offices;
publish the Firm’s updated Supplier Charter;
review and update the Firm’s Human Rights Policy;
plan a comprehensive BHR due diligence review and risk assessment in another of the Firm’s non-UK offices; and
establish a register of acknowledgment of the Firm’s Supplier Charter by suppliers.

Focused Approach

The Firm has a dedicated international BHR Group which continues to focus on issues of business and human rights, including modern slavery and human trafficking.

The full spectrum of environmental, social impact and governance aspects of the Firm’s transactions also continues to be covered by our dedicated Environmental, Social and Governance team.

The Firm’s Management Committee approved this statement on behalf of the members of Norton Rose Fulbright LLP on 26 October 2022.