Modern slavery and human trafficking statement?

This statement is made on behalf of Setfords Law Ltd (the “Firm”) pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”).

It constitutes the Firm’s modern slavery and human trafficking statement for the financial year ending 30 September 2023.

The Firm is registered in England and Wales and its head office is in Guildford. The Firm comprises approximately 755 people and provides a wide range of legal services to its clients. The Firm is committed to the highest standards of ethical behaviour and complies with all laws, regulations and rules applicable to its business. Furthermore, it is committed to taking steps to ensure that modern slavery and human trafficking does not occur in any part of its business or in its supply chains.

The Firm’s approach

To ensure adherence to the Act and to ensure that no slavery or human trafficking exists in the Firm’s business or, so as far as reasonably possible, in its supply chains, as reported in our prior statements the Firm has undertaken the following steps:

• a review of the Firm’s own recruitment policies and practices and its contracts of employment; and

• an analysis of the Firm’s suppliers and their business practices by requiring 2 of them to complete the Firm’s Modern Slavery Act questionnaire.

Suppliers were selected to participate based upon the following criteria:

1. The value of supplies made to the Firm;
2. The type of supply and whether goods provided are produced in jurisdictions that are high on the modern slavery index or services via personnel; and
3. Physical location of the supplier i.e. are they located in a jurisdiction that is high on the modern slavery index.

The responses received to these questionnaires have been analysed by the Firm and it is satisfied that as far as it is aware, no modern slavery or human trafficking can be detected in any of the Firm’s supply chains.

Supplier due diligence

The Firm’s procurement practice requires suppliers to explain their own compliance with the Act amongst other laws and regulations. This enables the firm to consider the supplier’s adherence to the Act and whether it is a suitable supplier to the Firm.

The Firm does not knowingly engage with businesses involved in modern slavery or human trafficking and will report any organisations where there are reasonable grounds to suspect their involvement. All of the Firm’s suppliers are expected to adhere to all laws and regulations applicable to their business.

Staff awareness

In tandem with this statement the Firm will also implement a Slavery and Human Trafficking Policy setting out the Firm’s stance in relation to modern slavery and human trafficking and its processes and procedures for minimising the risk of slavery and human trafficking in its own work force and supply chains. A reminder of the Firm’s policy is communicated each year when our statement is published.

The Firm also provides in-person training to those in the business who either deal with suppliers or the recruitment of staff. Training in the form of a guidance note on modern slavery will also be circulated to the entire firm in autumn 2023 and annually thereafter.

Responsible business strategy

As part of the Firm’s Responsible Business Strategy, the firm has designated Mike Brawley, (Managing Director – Legal Service Delivery) as a Responsible Business Manager for this purpose. During 2023/2024 we will be considering our supplier process to include the implementation of a Supplier Code of Conduct to ensure that our suppliers meet all legal and regulatory obligations (including obligations under the Act) as well as adhere to our ethical standards.

Responsibility

It is the responsibility of the CCO/COLP & compliance department to ensure adherence to the Slavery and Human Trafficking Policy.