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 (the Act) and constitutes our slavery and human trafficking statement for the financial year ending 30 April 2017.
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 reflects our continued 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 as well as a legal processing hub in Newcastle.
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 equipment and services; 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 or other services which are used by us in the provision of services to our clients.
The Firm has implemented a comprehensive human rights policy which was launched on Human Rights Day – 10 December 2016. The policy was the result of a collaboration between our Business and Human Rights Group, General Counsel Office and Compliance department. The policy is supported by Business and Human Rights training, an e-learning module which provides an introduction to the business and human rights agenda and an explanation of the main principles of the policy and their relevance to all our staff according to their specific functions.
Our Employee Handbook comprising all our employee-related policies was reviewed and amended in 2015 to take account of modern slavery. It has been followed throughout the financial year 2016/2017.
Our Ethical Reporting Policy is published on our intranet and it encourages 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 Employee Handbook 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.
The Firm conforms to the London living wage for its London employees.
In 2015/2016 the Firm carried out an impact assessment of our suppliers and started conducting due diligence in relation to our supply chains. Our Policy for Third Party Supply Contracts was revised to include modern slavery screening methodology principles and a Supplier Charter was introduced that sets out our expectations of suppliers in the wider business ethics sense. Good human rights practices form one set of principles the Firm expects our suppliers to adhere to. Members of staff and management involved in the procurement of goods and services have been trained to identify potential human rights issues and to use appropriate governance channels and protections in high risk situations.
The methodology and governance processes we have introduced were applied in the financial year 2016/2017. We conducted a review of the supplier of our principal outsourced business process operations. The review comprised desk top risk assessment, conversations and meetings with the supplier as well as a site visit. It confirmed suitable labour conditions and demonstrable respect for human rights by our supplier. Ongoing monitoring and reporting by the supplier has been reconfirmed.
An updated Policy for Third Party Supply Contracts was sent to all authorised signatories in May 2017.
All our London suppliers are required to pay at least the London living wage to their employees.
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 precedents for M&A, commercial and outsourcing transactions developed in 2016/2017 to reflect appropriate human rights principles were used by our corporate team.
Updated training addressing business and human rights, reporting obligations and modern slavery issues has been delivered at various events in London, including at our July 2017 Company Secretary Forum, and the results of our project on Human Rights Due Diligence survey conducted with the British Institute of International and Comparative Law, launched in October 2016, were made available publicly as well as to specific clients as part of their Modern Slavery Act or general compliance training programmes.
We set up three major KPIs for 2016/2017:
- We agreed to perform an in-depth review of one of our main suppliers.
The review of our outsourced operations mentioned in the supply chain section above comprised a desk top risk assessment, a meeting with the supplier and a site visit. It confirmed suitable labour conditions and demonstrable respect for human rights by our supplier. An agreed programme of ongoing monitoring and reporting by the supplier to us has been suggested and is being implemented.
- We agreed to introduce a human rights policy.
The policy was introduced, as set out above, on 10 December 2016.
- In order to support the introduction of our human rights policy, we agreed to roll out human rights training to all the staff and to achieve the training of 60% of our fee-earners.
The required 60% milestone was achieved by the end of our financial year 2016/2017.
We are happy to report that we have achieved all the above KPIs.
We have set the following KPIs for 2017/2018:
- Develop the existing client on-boarding and transaction opening process to include screening in the area of human rights for high risk clients
- Perform a due diligence review of one of the Firm’s offices outside the UK
- Progress the development of guidance and know-how for our human rights advisory services in another practice area
- Review regular monitoring of our strategic suppliers.
- We shall report on our performance against these KPIs in our 2017/2018 Modern Slavery Act statement.
As stated above, in 2016/2017 we concentrated on Firm-wide training of our staff to raise awareness of the general business and human rights principles, the way they relate to our values and what is incumbent on each of us in our daily work to contribute to the Firm’s respect for human rights. 60% of our fee-earners completed the Business and Human Rights training module. This training is now also provided to all new joiners.
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.
The Firm’s Management Committee approved this statement on behalf of the members of Norton Rose Fulbright LLP on 11 September 2017.
The Directors of Norton Rose Fulbright Services approved this statement on 11 September 2017.
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