Our commitment

We are a responsible and ethical business, committed to making a positive difference in all that we do and to uphold and further the values we have placed at the centre of our business: empathy, excellence, straightforward and together. We are committed to the eradication of slavery and human trafficking, both in our own business and in our supply chain.

This statement is made pursuant to the Modern Slavery Act 2015 and sets out the steps that Stevens & Bolton LLP and other relevant group entities [1] (“Stevens & Bolton”, “us”, “we”) have taken during our last financial year (1 May 2023 to 30 March 2024), and those we plan to take going forwards, to prevent slavery and human trafficking in our business and in any part of our supply chain.

Our business

We are a law firm, regulated by the Solicitors Regulatory Authority in England and Wales, providing legal and other ancillary services to clients predominantly based in the UK as well as to international clients. We are located in the UK, operating from a single office in Guildford, Surrey.

The firm is managed by its Board which is responsible for the firm’s operational and strategic management. The firm’s Risk Committee, which reports to the Board, oversees the management of risk within the business and evaluates risk and threats to the business, including those from our supply chain such as modern slavery risks.

Our suppliers

We aim to collaborate with our suppliers, build lasting relationships with them, support their work and together ensure slavery and human trafficking forms no part of what we do. Our suppliers provide services and products to support the firm’s operations in the following main areas:

• Business services operations, notably human resources, finance, business development, compliance, information services and facilities management (including building maintenance, cleaning and catering).
• Professional services, including external training, audit, tax and insurance services.
• Technology, including systems, software and IT equipment.

As a UK based law firm with suppliers predominantly based in the UK, we consider there is a low risk of slavery and human trafficking within our business and supply chain. However, we recognise that slavery and human trafficking is present within the UK economy, as well as being a global issue, and we have adopted (and continue to develop) measures to prevent it.

Policies and processes

We have adopted policies and processes that embed our commitment to prevent slavery and human trafficking in our business. They apply to everyone at the firm.

• Anti-slavery and human trafficking policy - which explains how employees can identify instances of modern slavery and where they can go for help.  
• Anti-bribery and corruption policy – which explains what constitutes bribery and corruption and how it may occur and sets out the processes everyone in the firm must follow in order to prevent bribery and corruption occurring.
• Employee screening policy – setting out the processes to be undertaken for all employees, both before and after joining the firm. The screening includes checks to safeguard against human trafficking or individuals being forced to work against their will.
• Whistleblowing policy – setting out how our people can raise concerns on a confidential basis about any wrong doing (including any concerns over slavery or human trafficking, how colleagues are being treated, or wrongful practices within our business or supply chain).
• Supplier protocol and contracts – setting out the procedures to be observed when engaging with suppliers. The protocol involves the use of a supplier due diligence questionnaire which requires suppliers to confirm if they have a modern slavery policy in place and to provide a copy. The questionnaire also requires suppliers to confirm if they vet their own suppliers and require them to meet specific standards and codes of conduct. We then conduct a risk assessment in relation to the proposed supplier, including in relation to the risk of slavery and human trafficking.

Assessing risk

Our people – We consider there is a very low risk of modern slavery or human trafficking within our business. We are a law firm, operating in the UK and employing mainly professional and other skilled and/or qualified and experienced staff. We are a member of the Living Wage Foundation. We remain vigilant, but consider that our policies and practices are proportionate to meet the modern slavery and human trafficking risks that we face. In the year covered by this statement we have had no instances of concerns reported.

Our clients - we have comprehensive client acceptance procedures that enable us to assess the risks involved in accepting instructions from a client. Any instructions that are considered to be higher risk (which may include concerns around slavery and human trafficking) are subject to further risk assessment and may be referred to our Risk Committee. 

Our supply chain – we consider there is a higher risk that modern slavery and human trafficking might exist in our supply chain. As a result, and also to ensure supplier quality, resilience and sustainability, we have this year implemented the supplier protocol and related practices referred to above which include carrying out a risk assessment on suppliers by our compliance team. We are in addition in the process of creating a database of suppliers which includes their location and the nature of the services or products provided. This helps us to assess and identify any higher risk activities or locations where relevant.

Performance indicators

Following implementation of our supplier protocol we will be better able to identify higher risk suppliers, track and review our supplier relationships and regularly review aspects such as modern slavery and human trafficking risks. The protocol will encompass both new and existing supplier relationships and contract renewals.

The introduction of a supplier management database will enable us to map modern slavery risks across our entire supply chain more comprehensively and will facilitate the regular risk review process.  

Going forwards

In the 2024/2025 financial year, we will:

• inform all our people on the risks of modern slavery and human trafficking, and provide training for staff most closely involved in supplier relationships;
• continue to focus on modern slavery risk mapping across our supplier chain; and
• progress our supplier management database to facilitate reviews of modern slavery risks.

This statement has been approved by the Board of Stevens & Bolton LLP on its own behalf and on behalf of Stevens & Bolton Trustees Limited.

Signed

 
James Waddell
Managing Partner
For and on behalf of the Board of Stevens & Bolton LLP

25 September 2024