Modern slavery and human trafficking statement

This statement is made on behalf of Penningtons Manches Cooper LLP pursuant to section 54(1) of the Modern Slavery Act 2015 (the Act) for the financial year ending 31 March 2024. Penningtons Manches Cooper is a limited liability partnership registered in England and Wales (registered number OC311575) and has the following subsidiaries: Penningtons Manches Cooper Singapore LLP and Bateson & Partners Law Firm trading as Penningtons Manches Cooper Greece. More information about the firm can be found on our website, penningtonslaw.com.

As an international law firm, Penningtons Manches Cooper is committed to practices that respect human rights in all our business dealings and relationships. We take steps to ensure that slavery and human trafficking does not occur within our business or supply chain. Penningtons Manches Cooper is a professional services firm which is regulated by the Solicitors Regulatory Authority; we therefore consider the risk of modern slavery occurring within our business to be low.

Approach

• Our policies reflect our zero tolerance approach to slavery and human trafficking. Our whistleblowing policy promotes the reporting of modern slavery concerns and provides protection for any employees that do so. Employees are informed of the policy at induction and the policy is accessible to staff at any time via our intranet.

• Penningtons Manches Cooper is committed to ensuring that all our people, including onsite contractors, are paid fairly for the work that they do. As part of this, we continue to be accredited as a “Living Wage” employer in the UK which means that anyone who is employed by the firm is at least paid the real living wage. We expect our outsourced providers to do the same.

• We comply with relevant employment legislation across all our offices and our recruitment due diligence process ensures that all our people have a right to work in the countries where we have offices/they are based. We only work with recruitment agencies that confirm that they are compliant with the requirements of the Act.

• We expect our suppliers to comply with the relevant legislation for their business and our procurement process includes verification of their compliance programmes. Checks on relevant suppliers on contract renewal aimed at detecting slavery, servitude, forced labour or human trafficking in our supply chain are also completed. Such checks are conducted by those overseeing procurement who will work alongside the firm’s best practice team. Where concerns arise, the best practice team will be informed and will take appropriate action.

• Our partners and employees are required to complete an e-learning module that sets out the impact of modern slavery and the part we all play in its prevention. This training is provided at induction stage and repeated every two years.

• The Penningtons Manches Cooper Foundation has a particular focus on vulnerable people including the homeless and victims of slavery and human trafficking. Our partners and employees are encouraged to take an active role in supporting the aims of the foundation, from fundraising to volunteering.

Our ongoing commitment

Our commitment to ensure that slavery and human trafficking does not occur in our supply chain remains a priority during our 2023/24 financial year. Action includes introducing a sustainable procurement policy to support management of our procurement activities. We intend to place more focus on worldwide procurement, having identified this as a potential higher risk area.

This statement has been approved by the firm’s Executive Board.

Helen Drayton
Chief Executive Officer