This statement is published on behalf of DLA Piper International LLP and DLA Piper UK LLP pursuant to Section 54(1) of the Modern Slavery Act 2015 in respect of the financial year ended 30 April 2019. References to "DLA Piper," "we," "us," "our" or the "firm" are to these named entities.
DLA Piper is committed to the highest standards of professionalism, ethical behaviour and integrity in everything we do and to contributing to the wellbeing of communities around the world, and has a zero tolerance approach to all human rights abuses. In this we are committed to opposing modern slavery in all its forms, and we do not tolerate it either within our business itself or within our supply chain.
As a firm, we are committed to adhering to the following core values in all our dealings with our clients, our people and our communities:
- Be supportive;
- Be collaborative;
- Be bold; and
- Be exceptional.
Our organisation structure and supply chain
DLA Piper International LLP and DLA Piper UK LLP are part of DLA Piper, a global law firm operating through a number of separately constituted and regulated legal entities which provide legal and other client services in accordance with the relevant laws of the jurisdictions in which they respectively operate. Further information about the DLA Piper global law firm, including information on the countries in which we operate, can be found on our website by clicking here.
DLA Piper is a professional services business, which predominantly employs professionally qualified and highly skilled people.
Our supply chain consists of goods and services procured to enable our people to deliver these services. Our relationships with sub-contractors, suppliers and their employees, business partners, agents and others working on their behalf (collectively "Third Parties") principally include professional services and consultancy, property, facilities management, human resources, information technology and marketing.
Our modern slavery strategy and due diligence process is developed and reviewed by a cross-functional team, including our Procurement, Property and Workplace, Responsible Business, Risk and Compliance teams to ensure that we take a coordinated approach across the firm. We have refreshed the workplan for this team to take account of the requirements to implement the new Supplier Assurance Framework ("SAF").
There have been no material changes to our organisational structure and supply chain since our last Slavery and Human Trafficking Statement.
Our policies in relation to slavery and human trafficking
Our policy framework includes a range of People and Procurement policies that outline our commitment to modern slavery and human trafficking risks in our business. During 2019, this policy framework was updated to ensure it is fit for purpose and to enhance our ability to communicate our policies to our people and other relevant stakeholders. Relevant policies include:
- Human Rights & Modern Slavery Policy: makes explicit our commitment to the United Nations Guiding Principles on Business and Human Rights, endorsed by the International Bar Association. This Policy confirms our commitment to respect and support international human rights, and in particular to the International Bill of Rights and the International Labour Organisation's Declaration on the Fundamental Principles and Rights at Work.
- Diversity and inclusion policy: encourages all our people to value diversity and respect each person's individuality, and to ensure that no partner, employee, agency worker, contractor, self-employed consultant, job applicant or ex-employee, client or third party receives less favourable treatment on the basis of colour, race, nationality, ethnic or national origins, sexuality or gender, disability, age or religion or belief.
- Ethics policy: embodies the key ethical obligations of the firm and our people and is pervasive in everything we do and in all our dealings, whether directly related to the provision of legal services or otherwise.
- Whistleblowing policy: offers individuals a confidential mechanism for disclosing suspicions or knowledge of possible impropriety to protect the firm, its brand, people and clients by delivering an early warning when something goes wrong. This includes matters pertaining to our supply chain which would include modern slavery.
- Incident reporting policy: offers individuals a mechanism for reporting breaches of firm policies and procedures, and errors, acts or omissions which result in breach of the legal or regulatory obligations of individuals or the firm. All our people have a personal obligation to report such incidents promptly and honestly when identified.
- Anti-bribery and corruption policy: sets out the firm's rules and what is expected of all our people. We expect the same standard of conduct from the firm's contractors and third-party service providers in all dealings on our behalf.
- Sustainable Procurement Policy: aligns with the Universal Declaration of Human Rights; UN Global Compact Ten Principles; UN Guiding Principles on Business and Human Rights and the Fundamental Conventions of the ILO. This policy, which includes an Ethical Code of Conduct, sets our expectations of third parties providing goods and services to DLA Piper.
We comply with all applicable employment law relating to employee terms and conditions, including pay, and have been accredited as a Living Wage Employer by the Living Wage Foundation.
The firm is committed to addressing the health and wellbeing of our people and provides access to support, delivered internally and by independent third-party providers which provide free and confidential advice and assistance on matters which include workplace concerns or issues.
All of these policies have been made available to staff on our Intranet pages within our Responsible Business area.
Strategy and supply chain due diligence
DLA Piper expects our suppliers to adopt the same high standards that we adhere to and have fair employment practices. These standards are reflected in the policies we generally share with our suppliers and ask them to commit to as part of a tender process. They include our Human Rights and Modern Slavery Policy and Sustainable Procurement Policy and specifically deal with instances of modern slavery by including, amongst other things, that our suppliers ensure that employment with them is freely chosen, child labour shall not be used, living wages are paid and working hours are not excessive.
We are revising and enhancing the process by which we identify and assess any actual or potential involvement in modern slavery in our supply chain. We are in the process of implementing a new Supplier Assurance Framework and new Supplier Code of Conduct ("CoC"), to be completed in the next 12 months. The SAF and CoC will apply to all suppliers, who will be asked the adhere to our new CoC regardless of risk tiering. The SAF has been developed to gather supplier information and to identify and assess actual or potential modern slavery risks. The objective is to equip DLA Piper to mitigate potential risks throughout the supplier engagement lifecycle from on-boarding through to performance improvement, gain further visibility into our supply chain, and to enable regular review of our data sets, risk register and ensure the continuous improvement of our approach to risk management.
This process will enhance our ability integrate findings of risk assessments and take appropriate action in response to identified risks, building on our approach where modern slavery red flags are raised and escalated to our specialist teams, which include, Risk and Compliance and Responsible Business who respond to the risk by developing a mitigation and/or management plan taking into account the specific context and circumstances and, where appropriate, engaging with other internal and external experts to develop effective responses.
Risk assessment and management
There have been no material changes to our principal third-party suppliers, who continue to be businesses which supply services related to the running of our premises (such as cleaners, caterers and security), and supply of the stationery and consumables needed to deliver our legal services to clients.
Similarly, those areas of our business and supply chain that carry a potential risk of modern slavery remain predominantly those which involve suppliers providing goods and services outside the UK, specifically Africa, the Middle East, South East Asia and Latin America. The steps we are taking to assess and manage these risks are outlined in this statement. We have undertaken and will continue to update such assessments and steps on an annual basis.
Our standard contract terms contain a clause by which we ask suppliers to commit to respecting and supporting international human rights and undertake that they will comply with their obligations under the Modern Slavery Act or any other similar legislation as well as any of our policies that are shared with them. We also reserve the right to terminate agreements with immediate effect when the supplier commits a material breach.
We have also included specific questions in the request for proposals in relation to tenders for new office and refurbishment projects, which has included projects in London, Edinburgh, Dublin, Hong Kong and Australia. Clauses are then included in the contracts for the procurement of goods and services in relation to these projects.
Over the past 12 months, there have been improvements to operational practices to enhance our risk management; for example, streamlining suppliers to minimise modern slavery risks in 2019 or developing a branded goods portal where suppliers have been able provide chain of custody assurance that the goods sourced were not exposed to modern slavery, which has also been promoted as a tool across multiple markets, including EMEA, Middle East, US and APAC. So far, 32 offices in 22 countries are using this platform which has minimised our exposure to modern slavery risks for these items. We continue to work on gaining further visibility across our office and enhance alignment between procurement practices across the firm.
DLA Piper has a whistleblowing facility that provides a confidential mechanism for individuals to disclose suspicions of impropriety.
Our cross-functional modern slavery team has held quarterly meetings to ensure progress in implementing our strategy and continuous review of priorities and performance.
In relation to supplier engagement, the frequency of these meetings is dictated by a number of factors, including consideration of the risks posed by involvement in modern slavery. Our contracts contain a contractual right to audit our suppliers. We also receive independent feedback on our performance from certain key clients who audit their relationship with us as their suppliers.
All members of the Procurement team undertake mandatory training on modern slavery and human trafficking. All employees are required to undertake mandatory training on relevant policies identified above.
At DLA Piper we are committed to contributing to the wellbeing of communities around the world. We encourage our lawyers to do pro bono work that is meaningful, impactful and supports those in need. Our lawyers work with individuals, NGOs and intergovernmental organizations to support access to justice and the protection and promotion of the rule of law around the world.
New Perimeter, our non-profit foundation, provides pro bono legal assistance in under-served regions across the globe to support social and economic development and sound legal institutions.
We are proud to be one of the first law firms subscribing to the United Nations Global Compact (UNGC). As part of our commitment to the UNGC we produce an annual 'Communication on Progress' against the UN Global Compact ten universal principles and broader UN development goals, the latest published version can be found on our website.
The DLA Piper Board approved this statement on behalf of the members on 12 February 2020.
Simon Levine, Managing Partner