Modern Slavery and Human Trafficking Statement

1. Introduction

This statement, made pursuant to section 54(1) of the Modern Slavery Act 2015, sets out Lyons Davidson Limited (LDL)’s actions to understand potential modern slavery risks related to its business and to put in place steps aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.  This statement relates to actions and activities during the financial year 2017/2018.

As part of the legal sector, LDL recognises that it has a responsibility to take a robust approach to slavery and human trafficking.  LDL is committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that those in its supply chains, and contractors, are free from slavery and human trafficking and comply with our values.

2. Organisational structure and supply chains

This policy covers the activities of LDL/Lyons Davidson Scotland LLP and File Dynamics Limited.

LDL is a law firm providing legal services to businesses and individuals nationwide.  File Dynamics Limited provides support functions to the business.  LDL operates from eight locations in England and Wales together with its associated practice in Scotland. Our supply chain comprises suppliers as expected in the running of a legal services office: including experts instructed to provide advice to our clients; counsel; facilities services; recruitment agencies; training providers and equipment providers.

The company currently only operates in the UK and has an annual turnover in excess of £36m.

3. Risk Assessment Process

Annually the company will undertake a risk assessment to determine the level of risk, relevant to our business and across our supply chain, from modern slavery and human trafficking.

Any risks identified from the above process will be prioritised and dealt with in accordance with comments set out below.

4. High-risk activities

LDL does not believe it has any particular activities or is involved with any countries which are high risk in relation to slavery or human trafficking.

5. Responsibility

Responsibility for LDL’s anti-slavery initiatives is as follows:

• Overall: LDL Board; 
• Policies: HR department;
• Risk assessment and due diligence: Compliance Director;
• Training: Training department.

6. Relevant policies and initiatives

LDL operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Whistleblowing policy: LDL encourages all its staff, clients and other business partners to report any concerns related to the direct activities, or the supply chains of, LDL.  This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.  LDL’s whistleblowing procedure is designed to make it easy for staff to make disclosures, without fear of retaliation.  Employees, clients or others who have concerns can raise these with us at any time;
• Employee code of conduct: LDL’s code makes clear to employees the actions and behaviour expected of them when representing LDL. LDL strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain;
• Corporate Social Responsibility programme: This documents LDL’s approach to its responsibilities in relation to social, ethical and environmental issues.  It deals with the way in which LDL aims to limit any adverse impact caused by LDL’s business in these areas, and to promote a responsible approach in the way it conducts business, which includes preventing slavery and human trafficking in its operations.

7. Due diligence

LDL undertakes due diligence when considering taking on new suppliers, and when reviewing existing suppliers, including:

• Assessing particular product or geographical risks of modern slavery and human trafficking in respect of each supplier;
• As part of contract negotiations/tender processes with any new supplier, considering  whether they are required to produce a Modern Slavery and Human Trafficking Statement, and reviewing any such statement and associated policies;
• Evaluating the modern slavery and human trafficking risks of each new supplier;
• Addressing any high-risk areas identified with the suppliers;
• Taking steps to improve any suppliers’ practices which cause concern, including requiring them to implement action plans;
• Where a potential frequent supplier is unwilling to co-operate with our enquiries  consider if that is a business relationship we wish to start;
• Invoking sanctions against suppliers that fail to address any identified issues, including terminating any relationship.

8. Performance indicators

In order to assess the effectiveness of our approach to modern slavery, LDL will be reviewing on an annual basis the following areas:

• Training for staff;
• Staff awareness;
• Reviewing existing supply chains; and
• Developing a new suppliers’ evaluation process.

9. Training

LDL will require all those involved in supply chain contracting and management to complete training on LDL’s policy and approach to slavery and human trafficking in order to better understand and respond to identified slavery and human trafficking risks.

10. Awareness-raising programme

As well as training staff, LDL will raise awareness of modern slavery issues to all staff via our intranet explaining:

• The basic principles of the Modern Slavery Act 2015;
• How employers can identify and prevent slavery and human trafficking;
• What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the company; and
• What external help is available.

11. Board approval

This policy has been approved by the company’s board of directors, who will review and update it annually.