Modern Slavery Statement
Statement pursuant to section 54 of the Modern Slavery Act 2015 for the financial year ending 31 December 2021.
This statement is published on behalf of Wilmer Cutler Pickering Hale and Dorr LLP, a legal practice, authorised and regulated by the Solicitors Regulation Authority (SRA) under registration number 287488, and references to “we” and “the firm” are to that entity.
We are committed to achieving high standards of ethical behavior in the conduct of our business and to acting with integrity in all our business relationships. We do not tolerate slavery, human trafficking or abusive or unfair treatment in any part of our business or in any part of our supply chain.
Structure and Supply Chains
We are a limited liability partnership established in Delaware, USA, with an office in London, UK. We are a solicitors’ practice and as such are regulated by the Solicitors Regulation Authority. We have no subsidiaries but are affiliated to a US law firm of the same name which has subsidiaries in Germany, Belgium and the People’s Republic of China. Our clients are based all over the world.
We have considered our current suppliers and our business by size and risk profile and assessed the risk of slavery or trafficking being present in our annual review in 2021. Our primary suppliers include suppliers of office and professional support services and regulated law firms and barristers. None of our suppliers are engaged seasonally and we do not have employees on seasonal contracts. We do occasionally engage lawyers on temporary contracts through reputable agencies. We have internal procedures in place to ensure adequate procurement pricing and prompt payment of our suppliers. We found no cause for concern in our annual review in 2021. We have determined that our business is low risk for slavery and human trafficking.
Policies in relation to slavery and human trafficking.
We have an internal policy on Anti-Slavery which we review and, where necessary, update on an annual basis.
We have whistleblowing policies and procedures and our employee code of conduct contains grievance procedures.
Identification of Risks and Steps we take to Identify and Manage those Risks.
We are continuing to take steps to ensure that slavery and human trafficking play no part in our supply chain and our business. We undertake an annual review of our key suppliers and will meet with our key suppliers at least annually now that normal business practice has returned after the pandemic.
The main area of risk in our supply chain and our business identified through our annual review in 2021 was in relation to the hiring of outsourced catering staff. Appropriate due diligence is conducted when we engage with such suppliers to mitigate that risk. In practice we only use reputable outsourcing agencies and we comply with all local laws and regulations. The national restrictions imposed in 2021 meant that our use of outsourced catering staff was greatly reduced. As normal business practice returns we expect to increase our use of outsourced catering staff and we will again take all reasonable steps to mitigate the risk of slavery and human trafficking in this area.
Due Diligence Processes
We have maintained our procurement procedure throughout the year with regard to the engagement of all new contractors to the Firm. Risk of slavery remains one of the evaluation criteria behind our selection of new suppliers.
Effectiveness in Preventing Slavery and Human Trafficking
We found no evidence of Slavery or Human Trafficking in our annual review. We have had no grievance claims or complaints made through our whistleblowing processes in relation to modern slavery or human trafficking.
Training and Capacity Building
We train appropriate members of the firm. We have introduced Modern Slavery as a topic in our induction training.
Wilmer Cutler Pickering Hale and Dorr LLP
15 June 2022