1.1.1 Our business is about providing responsible legal and other professional services to enable our clients to manage and address business risks. A commitment to behaving responsibly is at our core and it extends to everything we do, and to those with whom we interact.
1.1.2 We operate as a multinational business under Pinsent Masons International LLP which is the governing body for those entities which trade under the Pinsent Masons name and brand ("Pinsent Masons group"). The main trading entity in the UK is Pinsent Masons LLP (head-quartered in London). The Pinsent Masons group is regulated by the appropriate regulatory body in those jurisdictions in which it operates. We have around 4,000 people working in different jurisdictions. Details of our corporate structure and where we operate can be found on our main website - Legal Notices.
1.1.3 Pinsent Masons International LLP, Pinsent Masons LLP and its subsidiary Pinsent Masons Services Limited meet the criteria in section 54 of the Act and are therefore required to prepare a slavery and human trafficking statement. This Transparency Statement covers these entities.
1.1.4 The Pinsent Masons group has a global turnover of c£605.8 million.
1.2.1 We refer to forced or bonded labour, including human trafficking and modern slavery, collectively as "forced labour" in this Transparency Statement. In this section we describe our supply chain and consider the risks of forced labour.
1.2.2 We provide legal and other professional services on a multinational basis. The supply chain that supports our business and provides the platform that enables us to provide these services to clients is broad. It comprises a wide range of suppliers, from small/medium enterprises (SMEs) to global corporates.
1.2.3 To illustrate the breadth of our supply chain, it encompasses products and services from IT hardware and software, knowledge management services, office design, fit-out and maintenance, recruitment agents and temporary staff provision, cleaning and catering services, through to outsourced services such as document production.
1.2.4 The supply chain that supports the Pinsent Masons group is primarily based in the UK, however, due to the range of products and services we require and the location of offices in our multinational business, products and services are procured from jurisdictions where there is a higher risk of forced labour such as countries within Asia, the Middle East and Africa.
1.2.5 The range of products/services in our supply chain and the wide range of jurisdictions in which these are sourced mean that we consider the tiers below our immediate suppliers to be our primary area of risk from a forced labour perspective.
1.3.1 We are committed to:
a) ensuring that there is no forced labour in any part of the Pinsent Masons group or within our supply chains; and
b) implementing and enforcing effective systems and controls designed to address the risk of forced labour.
1.3.2 We act ethically and with integrity in all our business relationships.
1.3.3 Procurement in the UK is largely controlled by our Central Procurement and Contracts team ("CPC") operating a centre led model and working with around 70 buyers spread across the various business functions. Whilst many of the goods and services required by our offices outside the UK are sourced centrally in the UK, procurement and contracting guidance is provided by CPC for buyers outside the UK for local procurement and support is provided when requested.
1.3.4 We partner with and/or are members of a number of organisations who help shape our commitment to doing business responsibly by providing us with specialist advice and support. This includes Stonewall, Business in the Community, Working Families, Business Disability Forum, WEConnect and MSDUK. We are a signatory of the UN Global Compact.
2.1.1 Our Procurement Policy, which is regularly updated, governs procurement by the Pinsent Masons group and incorporates our approach to forced labour. It is made available to all staff through our intranet. The Procurement Policy, Procurement Gateway and associated intranet guidance and templates set out the processes that all staff are expected to follow to avoid the risk of forced labour in our supply chain, as further described in sections 3 and 4.
2.1.2 We require key suppliers to commit to our Supplier Code of Conduct, which helps us to address issues of forced labour (amongst other aspects of responsible business). Our Supplier Code of Conduct emphasises the need for active monitoring and audit through day to day management processes to ensure and maintain compliance with the Supplier Code of Conduct.
2.2.1 With respect to global recruitment and employment of our own people we have implemented a number of measures as part of our commitment to ensuring there is no forced labour.
2.2.2 We operate a preferred supplier list in relation to the recruitment agencies we work with and new suppliers are asked to commit to our Supplier Code of Conduct.
2.2.3 We undertake background checks in relation to new starters to our business relevant to the jurisdiction they will be working in and to the extent legally possible in the various jurisdictions.
2.2.4 Pinsent Masons is an accredited Living Wage Employer. This means that all of our people in the UK, regardless of whether they are direct employees or third-party contracted staff, receive a minimum hourly wage. The Living Wage is an hourly rate set independently and updated annually and it is calculated according to the real costs of living.
3.1.1 A set of robust checkpoints are incorporated into our procurement process, from an initial risk assessment and sourcing requirements (business case), through the request for tender/proposal, and on to recommendation and contract approval, to ensure that at each stage the risks are considered, appropriate information is gathered and that supplier selection decisions are taken in the light of the risk of forced labour.
3.1.2 Our buying process and associated supplier due diligence include an initial on-line risk assessment (known as our Procurement Gateway) that is carried out at the outset of procuring any goods and/or services to identify and address risks, including risk of forced labour. If the forced labour risk is flagged, further due diligence is undertaken and the outcome forms part of the supplier evaluation process.
3.2.1 We incorporate a standing agenda item on responsible business in our quarterly and annual supplier reviews with our key suppliers. Those involved in managing contracts, particularly the larger contracts in the UK relating to high-risk services e.g. cleaning and catering, have a high level of awareness of the signs of forced labour as a result of compulsory training and guidance provided by CPC.
3.2.2 If there is any change in risk profile and/or after a set period, the Procurement Gateway referred to above requires all contract renewals to be risk assessed (including for forced labour) before proceeding.
3.2.3 Our buying community also remain vigilant for ‘red flag’ indicators of modern slavery during the course of the supplier relationship and are required to report any suspicions accordingly.
4.1.1 We have established a system for assessing the risk of forced labour associated with suppliers and/or potential suppliers. The system enables a supplier risk rating to be produced based on various risk factors such as country and service/product type. We recognise that particular types of suppliers are likely to give rise to a higher risk of forced labour, in particular those utilising lower-wage staff such as security, couriers, cleaning, etc., and those utilising manufacturers in low-wage countries, such as IT hardware, and have weighted those types of suppliers accordingly.
4.1.2 We also use various well established indices to quantify the risk associated with certain countries. Where, through risk assessment, we perceive a particular risk of forced labour, we will undertake enhanced due diligence, asking additional questions during the procurement process tailored to the specific risks and utilising the resources and influence available to us to ensure the supplier meets acceptable standards.
4.1.3 The Procurement Gateway asks questions about the nature and location of the required supply designed to flag risks of forced labour early in the sourcing process, and enables enhanced due diligence and mitigating action to be undertaken well before committing to that supplier.
4.1.4 When it is identified that a supplier or contract may require an enhanced risk assessment, we have leveraged technology to assist with assigning questionnaires to the relevant stakeholders at the supplier, and the subsequent automated scoring of responses to assess risk level. These questions look at the suppliers’ own policies and procedures, commitment to tackling modern slavery at senior level, their own supply chain and knowledge of it and any training or awareness campaigns they provide to their own employees.
We have incorporated provisions into our standard template supplier contracts to require suppliers to manage and reduce the risk of forced labour. The standard provisions require suppliers to: recognise a commitment to removing forced labour and to take steps to avoid forced labour in their business and supply chain, provide information to us in relation to any instances of forced labour and to warrant to us that no investigative or enforcement proceedings have taken place. We also retain the ability to terminate contracts where the supplier has failed to deal adequately with any such risks. We have a more stringent set of provisions to use in cases where there is a high risk of forced labour.
5.1 Our targets for measuring our performance in respect of our forced labour processes and planned improvements and training are as follows:
5.1.1 100% of CPC team members and 90% of the wider buying community to have undertaken advanced training on forced labour (as referred to in section 6.2) by October 2022. Advanced training should be completed on alternate years from the forced labour training for all staff;
5.1.2 85% of all staff globally to have undertaken the forced labour training (as referred to in section 6.1) in 2023 and completed bi-annually;
5.1.3 monitor on a monthly basis initial and secondary assessment processes for addressing forced labour (as outputs of the Procurement Gateway);
5.1.4 issue our updated forced labour risk assessment to existing and long-established suppliers when a contract is up for renewal.
5.1.5 ensure there are appropriate forced labour provisions in contracts with key suppliers;
5.1.6 record all decisions to reject suppliers on the basis of a high risk of forced labour assessment; and
5.1.7 continue to utilise technology to assess and automate the scoring of new suppliers for forced labour risk and to leverage the information to enhance our supply chain mapping.
6.1 Together with one of our suppliers of regulatory training services, we have developed an on-line forced labour training course tailored to the Pinsent Masons group. This training is in the form of a self-check and provides an introduction to the risks of forced labour, how those risks may manifest within our supply chain, the policy and processes we have in place to avoid those risks and the red flags to look out for. This self-check training was rolled out to all Pinsent Masons group staff globally in October 2021 with 93% completion.
6.2 Those individuals within the firm who have responsibility for sourcing and managing suppliers are required to complete a detailed on-line forced labour training course. That detailed training is in addition to the general training referred to above, as well as the Procurement Policy (readily accessible to all buyers), the guidance on the CPC intranet site and the procedures signposted by the Procurement Gateway. The detailed training course was rolled out in October 2022 with 100% completion by CPC team members and 95% completion by the wider buying community. Further detailed training will be rolled out again in October 2024.
6.3 For this financial year we have an appointed Modern Slavery Compliance Officer ("MSCO") for the Pinsent Masons group. All forced labour queries in respect of our business and our supply chain should be reported to the MSCO. This role has been communicated to all staff within the Pinsent Masons group by email and included in the training course.
6.4 Further briefings and guidance on forced labour risks will be provided by CPC to buyers in connection with the Procurement Gateway. A member of CPC provides training and guidance to our buyers as 50% of their role, including training and guidance on forced labour.
This Statement is made pursuant to section 54 (1) of the Act and constitutes Pinsent Masons' forced labour statement for its financial year ended 30 April 2023.
The Board of Pinsent Masons International LLP is responsible for implementing this Statement and its objectives and providing adequate resources, training, and investment to ensure that forced labour is not taking place within the Pinsent Masons group or within its supply chain.
This Statement will be reviewed at least annually and made available on our website.
Andrew Masraf, Senior Partner, signed
On behalf of the members of Pinsent Masons International LLP.
On behalf of the members of Pinsent Masons LLP.
The board of Pinsent Masons Services Ltd approved this statement on 20 October 2023
Laura Cameron, Director of Pinsent Masons Services Ltd signed