Introduction
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes The Irwin Mitchell Group’s slavery and human trafficking statement for the financial year ending 30 April 2022.
The Irwin Mitchell Group of companies has made a commitment to being recognised as a leading responsible business and is a signatory of the United Nations Global Compact.
The Group has increased focus on ensuring there is transparency in its supply chains, responsible procurement of new suppliers and takings steps to prevent modern slavery and human trafficking.
Part of the Irwin Mitchell Group, Irwin Mitchell LLP is unique, both in its culture and its approach to law. Nationally acclaimed, with international capabilities, Irwin Mitchell LLP is one of a few law firms to provide a diverse range of legal services to businesses and private individuals. It has a strong customer service culture and a high level of client retention.
Irwin Mitchell LLP reassessed its risk levels due to the Coronavirus (COVID-19) pandemic and recognised that the working environment had to change substantially to protect our employees, clients and local communities.
Our Structure
The Irwin Mitchell Group consists of Irwin Mitchell Holdings Limited, the parent company of Irwin Mitchell LLP and a number of subsidiaries. It has an established office network covering England and Wales. Irwin Mitchell Scotland LLP is a separate Scottish legal practice regulated by the Law Society of Scotland and has an office in Glasgow. Irwin Mitchell Scotland LLP sits outside of the Irwin Mitchell Group.
Irwin Mitchell LLP provides a wide range of legal services to over 200,000 clients a year, with particular strengths in litigation. The firm comprises the Client Services Team, Commercial Growth Team and Group Services. It adopts a partnership approach to its clients, underpinned by the latest technology, innovative pricing and excellent service delivery.
Irwin Mitchell LLP largely has a UK centric supplier base and is therefore considered low risk in engaging in modern slavery or trafficking activities. Despite this, Irwin Mitchell LLP takes modern slavery risk very seriously.
Our Group Policies
As part of our ongoing commitment to combating modern slavery, we review annually a number of our Group wide policies, including but not limited to:
Whistleblowing Policy
Responsible Business Policy
Health & Safety Policy
Gifts, Hospitality & Charitable Donations Procedure
Anti-Bribery & Corruption Policy
Procurement Policy
Contracts Policy
Employment and recruitment policies which comply with all UK law
Ways of Working Guidance (including the Flexible by Choice Framework).
Our whistleblowing policy includes a mechanism for reporting genuine suspicion of any criminal conduct or breach of a legal or professional obligation, by anyone in the firm or the Group, or by a client or contractor, which includes instances of modern slavery.
During the Coronavirus pandemic, the firm and the Group followed all government guidelines to safeguard its employees and local communities.
The firm continues to operate on a ‘Flexible by Choice (FBC)’ basis, a hybrid of home, office working and other workspace working. This is based on trusting colleagues to do the right work, at the right time, in the right way. A ‘Ways of Working (FBC) Hub is available on the firm’s intranet site so colleagues have access to all vital information, policies and procedures whilst working remotely in different workspaces. This means colleagues have access to appropriate support and can remotely continue to learn and develop themselves on relevant topics including the issue of modern slavery.
Our Supplier Due Diligence Processes
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chain, we have taken the following steps:
We are reviewing and developing our supplier segmentation process to ensure appropriate levels of oversight and frequency of review
We have put checks in place to ensure that our suppliers have policies for ESG issues and are working to improve this process so that no matter what stages of maturity our suppliers are at, we can be rest assured that they are demonstrating progress
We also require our critical suppliers to demonstrate their responsible business credentials which are evaluated and scored, as part of our tender process or as part of our on-going supplier management approach
We have reviewed our comprehensive supplier due diligence assessment matrix to ensure additional risks, post peak Coronavirus pandemic, are considered and assessed as part of our procurement process and routine supplier audits
We are implementing our Sourcing Statement of Intent to ensure suppliers are aware of our high standards of safe working and expectations around conduct and behaviours to encourage a collaborative and compliant based working relationship
We are reviewing and further developing our existing clauses around Modern Slavery to ensure suppliers are contractually committed to operational compliance
We will ensure key stakeholders across the Group are kept up to date on Modern Slavery requirements via enhanced training.
The Group has robust and effective policies, and collaborative working amongst the Group Services function, which ensures that now and in the future, the Group’s approach to the procurement and on-boarding of new critical suppliers is robust, transparent and risk-based.
These steps have been taken to enable us to:
Establish and assess areas of potential risk in our businesses and supply chains
Monitor potential risk areas in our businesses and supply chains
Reduce the risk of slavery and human trafficking occurring in our businesses and supply chains
Provide adequate protection for whistle-blowers.
Risk and Compliance
The Irwin Mitchell Group has taken steps to evaluate the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain. We do not consider that the Irwin Mitchell Group operates in high-risk sectors or locations.
The Irwin Mitchell Group does not tolerate slavery and human trafficking within its supply chains and would immediately seek to terminate its relationship with a supplier where evidence of a failure to comply with the Group’s policies was discovered.
Approved by the Irwin Mitchell Holdings Limited Board.
Andrew Tucker
Group Chief Executive
Irwin Mitchell Group
October 2022
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