Slavery and Human Trafficking Statement

This statement is published on behalf of Pillsbury Winthrop Shaw Pittman LLP. Pillsbury Winthrop Shaw Pittman LLP is a Limited Liability Partnership registered in England and Wales under Number OC303330 and regulated by the Solicitors Regulation Authority (Pillsbury).

Pillsbury is committed to preventing acts of modern slavery and human trafficking from occurring within its business and so makes this statement to set out the steps taken, as a responsible and ethical provider of professional business services, to ensure that no forms of modern slavery or human trafficking occurs anywhere within our business operations or within our supply chain. 

Our Firm

Although it is a separate entity, Pillsbury is associated with a leading international law firm of the same name registered in Delaware USA with approximately 650+ lawyers and 700+ support staff located in 20 offices across the US, Europe and Asia.  Pillsbury prides itself on, and is fully committed to, providing the highest standards of legal services across a number of jurisdictions and industries, with professionalism and integrity.

For further information on Pillsbury, our business or our structure please click here

Compliance

As a professional services firm, we have stringent policies and processes already in place to ensure fair and equal employment rights and pay, working time protections and protections against any form of discrimination, including but not limited to harassment, which both protect our staff and set out the principles by which our staff must deal with any third parties.  We consider the risk of modern slavery and human trafficking existing within our business to be extremely low.

A key part of our slavery and human trafficking strategy is to promote awareness in the form of training for those Pillsbury personnel who have responsibility in managing external suppliers (our supply chain).  The training will cover the key aspects of the Modern Slavery Act 2015, this Statement, and the various options available to report any concerns with our Pillsbury Compliance Team as well as externally through the Modern Slavery Helpline.

Pillsbury has appointed a team to undertake a review of our recruitment, selection, hiring and promotion processes, as well as our supply chain management, at a yearly compliance meeting.  The team consists of the Managing Member, the Compliance Officer for Legal Practice, the Compliance Officer for Finance and Administration, the London Director of Administration, and the London Senior HR Advisor.  Any action points will be filed on Pillsbury’s Compliance Register.

Supply chain

Pillsbury’s supply chain is relatively simple with many of our key suppliers engaged in roles such as security, facilities and building management, cleaning, office supplies, recruitment and in qualified areas such as barristers, accountants, tax consultants and worldwide legal professionals.

We expect, and will require, our suppliers to

  1. conduct their businesses with the same professional and ethical standards to which we adhere; and
  2. operate fair employment practices. 

Pillsbury is accredited as a London Living Wage Employer and requires its suppliers to ensure that their workers are paid the living wage of the jurisdiction in which they are based (or the London living wage, if they are based in London), that working hours are not excessive, that no child labour is used and that their employment is freely chosen. For further information on the Living Wage Foundation please click here.

To ensure that the above principles are adhered to Pillsbury has taken the following steps:

  • We regularly engage with our suppliers to create open and respectful relationships and we review our suppliers at least once per year, usually through face to face meetings, to ensure that all suppliers we engage with operate in a fair and ethical manner.
  • At these review meetings we expect and require our suppliers to confirm that their operations comply with the principles Pillsbury promotes.
  • In the event that we become aware of a case of modern slavery occurring within our supply chain, we will work with the supplier to implement remedial action within an agreed timeline. Any continued or material breach will carry the risk of termination of their engagement.

Policies

Pillsbury has several policies that, together with our Anti-Slavery and Human Trafficking Statement, address our approach to complying with the Modern Slavery Act 2015 and the steps necessary to prevent instances of non-compliance occurring within our business and our supply chain.  These include:

  • General standards of performance and expectations of conduct: we have strict policies, practices and highly ethical standards of behaviour which we expect all of our partners, employees, contractors and consultants to follow. In addition to this, Pillsbury requires suppliers to commit to respecting and promoting international human rights, and undertake that they will fulfil their obligations under the Act, or any other corresponding legislation. We also reserve the right to terminate agreements with immediate effect where the supplier commits a material breach relating to modern slavery.
  • Equality and Diversity Statement: we place strong emphasis on respectful working relationships and in creating an environment which supports equality and diversity.
  • Whistleblowing policy: we encourage and support all staff to report any concerns relating to the direct activity or the activity of our supply chain. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.  Our policy is designed so that employees may easily disclose any concerns without fear of retaliation.
  • Health and Safety policy: we are committed to providing a safe and healthy working environment for all of our partners, employees, contractors and consultants.
  • Anti-Bribery policy: our rules and principles with regard to bribery and corruption apply to all of our partners, employees, contractors and consultants and is strictly enforced.

Commitment to corporate social responsibility

Pillsbury is committed to contributing to deprived sections of the community in a number of ways including through supporting a number of non-profit and charitable organisations. Pillsbury enables this to be accomplished by encouraging those within the organisation to do pro-bono work that impacts and supports those in need. Through the Pillsbury Foundation, Pillsbury also supports programs to end hunger in local communities. From associates to senior partners, every lawyer is expected to perform a minimum of 25 hours annually in service to Pillsbury’s pro-bono clients.

Our corporate social responsibility page can be accessed here.

Steps taken during our 2017-2018 financial year

Our team met during the 2017-18 financial year.

The team has obtained and reviewed information available concerning our business and supply chains.

The team found that:

  1. There have been 0 incidents of modern slavery from the previous financial year. This evidences Pillsbury’s commitment to ensure that no forms of modern slavery or human trafficking occurs anywhere within our business operations or within our supply chain, and confirms that the we have adequate safeguards in place to combat modern slavery.  
  2. All Pillsbury staff have completed online modern slavery training to help raise awareness amongst the team so that they are able to prevent any risks, and understand Pillsbury’s policy on responding to any risks they identify.

Actions

Following the above findings of our team, over the next 12 months Pillsbury aims to:

  • Draft, publish and socialise a formal London office Anti-Slavery and Human Trafficking policy to those of our affiliated offices where it would be an appropriate and proportional exercise to do so.
  • Consider whether a formal Supplier Code of Conduct may be advisable to outline the ethical requirements we plan to place upon our suppliers, their subsidiaries and any contractors. In the event we elect to adopt a Supplier Code of Conduct, all of our supply chain will have to adhere to the Supplier Code of Conduct in order to do business, or to continue to do business with us.
  • Continue to provide annual training to staff and train key London office stakeholders to raise awareness, to enable these members of our business to understand the requirements of the Act and to provide them with the knowledge and tools to flag potential issues.
  • Issue a Modern Slavery questionnaire to those of our existing suppliers, if any, that we have identified as high risk, in order to assess their current Anti-Modern Slavery policies and controls. When responses are received, they will be reviewed and the risk assessment of the supplier will be updated accordingly. Where we identify a potential risk, it will be investigated and mitigated through activities such as enhanced due diligence.

Approval

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 with respect to the financial year ending 30 December 2017. It will be reviewed on an annual basis, and is approved by:

Ed Perron, Managing Member

On behalf of the Members of Pillsbury Winthrop Shaw Pittman LLP