Modern slavery is a heinous crime and a morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain.
At Foundry Chambers, we have a zero-tolerance approach to modern slavery, and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking during the financial year 2019.
Our Business & Supply Chains:
Foundry Chambers provides advice and advocacy for individual and corporate clients and all prosecution agencies, local authorities and regulators across the full spectrum of the criminal law and in civil and regulatory matters involving allegations of financial wrongdoing, professional misconduct and tax litigation. Our membership also includes established practitioners in the fields of extradition, public law and immigration. The range of work undertaken and specialist teams of barristers make Foundry Chambers a single port of call for clients looking for solutions to matters crossing different legal disciplines. The office is located in central London, UK.
We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier’s reputation, respect for the law, compliance with health, safety and environmental standards, and references.
We haven’t been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act promptly and report it to the authorities.
In the current year, we plan to conduct a risk assessment of our supply chain by taking into account the business services rendered by the suppliers, the presence of vulnerable demographic groups, a news analysis and the insights of labour and human rights groups and the risk profile of supplier countries based on the Global Slavery Index. This assessment will determine our response and the risk controls that we implement.
Foundry Chambers operates the following policies for identifying and preventing slavery and human trafficking in our operations:
- Whistleblowing Policy – we hereby encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation.
- Code of Conduct – we encourage our employees to do the right thing with company policies which clearly state the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.
- Purchasing Process – we plan to update our purchasing process and supplier contracts to make explicit reference to slavery and human trafficking.
Supplier Due Diligence:
Foundry Chambers conducts due diligence on all new suppliers during on-boarding and on existing suppliers at regular intervals. This includes:
- Assessing risks in the provision of particular services
- Where relevant auditing the suppliers, and their health and safety standards, labour relations and employee contracts
- Where relevant requiring improvements to substandard employment practices
- Where relevant sanctioning suppliers that fail to improve their performance in line with our requirements
If relevant based on the risk assessment mentioned above, we plan to require suppliers to attest that they don’t use any form of forced, compulsory or slave labour, their employees work voluntarily and are entitled to leave work, they provide each employee with an employment contract that contains a reasonable notice period for terminating their employment, they don’t require employees to post a deposit/bond and don’t withhold their salaries for any reasons, they don’t require employees to surrender their passports or work permits as a condition of employment.
Foundry Chambers plans to raise awareness of modern slavery issues by putting up posters where relevant in our office and circulating an email that is focused specifically on modern slavery to all our staff, which explains our commitment in the fight against modern slavery, red flags for potential cases of slavery or human trafficking and how employees should report suspicions of modern slavery.
In addition to the awareness programme, Foundry Chambers plans to roll out an e-learning course to all employees and where relevant supplier contacts, which covers various forms of modern slavery in which people can be held and exploited, the size of the problem and the risk to our organisation, how employees can identify the signs of slavery and human trafficking, including unrealistically low prices, how employees should respond if they suspect slavery or human trafficking, how suppliers can escalate potential slavery or human trafficking issues to the relevant people within their own organisation, what external help is available for the victims of slavery, what terms and guidance should be provided to suppliers in relation to slavery policies and controls, what steps Foundry Chambers will take where relevant if a supplier fails to implement anti-slavery policies or controls plus an attestation from employees that they will abide by Foundry Chambers’s anti-slavery policy.
Measuring How We’re Performing:
Foundry Chambers has defined a set of key performance indicators and controls to combat modern slavery and human trafficking in our organisation and supply chain. These include how many employees have completed mandatory training and where relevant how many suppliers have confirmed compliance.
This statement covers 1 April 2019 to 31 March 2020
Updated: August 2019