This statement is published on behalf of Greenberg Traurig, LLP (“GT” – a limited liability partnership (registered in England & Wales),), pursuant to section 54 of the UK Modern Slavery Act 2015 (the “Act”). This statement constitutes our modern slavery and human trafficking statement for the financial year ending 31 March 2023 and sets out the steps we have taken to to address slavery and human trafficking risks in our business and in our supply chain.
Greenberg Traurig, LLP (“GT”), is a law firm authorised and regulated by the Solicitors Regulation Authority. GT is the London office of the global law firm Greenberg Traurig. GT employs over 120 lawyers who provide legal services to a broad range of clients in the UK and across the globe.
GT is committed to the highest standards of ethical, moral and legal business conduct. GT has a zero-tolerance approach to all forms of slavery, servitude, forced or compulsory labour and human trafficking (collectively referred to as “Modern Slavery”). We have put in place practices that we continue to develop, to combat all forms of Modern Slavery within our supply chains or in any part of our business.
GT respects human rights standards and promotes fair reward and recognition of diversity, inclusion and equal opportunity in all employee dealings, including decisions on hiring, remuneration, training and development.
Zero Tolerance to Modern Slavery
GT has a zero tolerance approach to all matters of human rights or slavery violations. We are in the process of preparing a dedicated Anti-Modern Slavery Policy (the “Policy”) which reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to reduce the risks of Modern Slavery in our business or our supply chains.
All GT personnel are encouraged to report any concerns they have regarding any legal or ethical matter, including any awareness or suspicions of Modern Slavery in our business or supply chains and all reports will be treated with appropriate confidentiality, to the extent permitted by law. Our zero-tolerance approach, and the soon to be finalised Policy, applies to all GT personnel.
Our Supply Chain Relationships
Our business is predominantly office-based and we have a relatively simple and limited supply chain supporting these operations. Our key suppliers and vendors are businesses that provide the goods and services we need to operate our offices, and to support the provision of legal services to our clients. We therefore engage suppliers for the provision of services in the areas of recruitment, use of temporary staff, document management, review providers, technology solutions and other support services directly linked to the provision of legal advice and to support the business. We may also require project-specific support (for example, in connection with an office move) in addition to everyday operational support, including facilities management services such as catering, cleaning, pest control and maintenance of equipment.
We also engage the professional services of barristers and other specialist advisors or experts.
Supplier Due Diligence
We strive to retain the best personnel and supply chains to help run and grow our business. The Policy is supplemented by active and appropriate due diligence to ensure that risks arising from Modern Slavery in relation to our suppliers and vendors are identified and managed appropriately.
We choose our suppliers and vendors with care through a number of evaluations, including based on their reputation and integrity. The process by which we select our suppliers and vendors differs depending on the nature of the services and products they are providing. A risk-based approach is used to determine the level of due diligence appropriate to be undertaken in respect of each supplier. None of our supplier relationships are considered to be high risk and therefore no enhanced due diligence steps have been taken to date.
In the year ending 31 March 2023, we have re-evaluated for the procurement of new suppliers and vendors, and for the renewal of existing supplier contracts. In particular, we require new suppliers and vendors to provide information on the policies they have in place to address modern slavery risks in their business and supply chains and we are developing procedures to ensure all new suppliers and vendors provide us with information to help us determine the risks to us in entering into a business relationship with them.
Risk & Effectiveness
As a regulated provider of legal services and employer of predominantly professionally qualified and highly skilled people, we have assessed that the risk of Modern Slavery within our business is low. We apply robust policies and procedures in relation to employment screening (including work eligibility checks) and employment conditions.
We maintain an up-to-date list of all suppliers and vendors, none of which have been identified as high risk.
To date, we have not identified any occurrence of Modern Slavery in our supply chain, nor have we identified any risks of Modern Slavery that we have not been able to resolve through additional due diligence or engagement with the supplier.
We are committed to ensuring that all GT personnel involved in procurement have the knowledge and understanding to recognise the key issues and risks relating to Modern Slavery and how these are to be addressed in our supply chain. GT requires all new staff to complete compliance induction training, which equips employees with the skills necessary to identify the signs of wrongdoing and to report it. We have in place software which allows personnel to report ethical misconduct anonymously.
We will continue to review our policies, processes and controls to ensure they are operating effectively and proportionately to the risks faced within our business and supply chain. We will continue to make efforts to identify any significant risks in our business and supply chain and implement any actions appropriate or necessary directly with suppliers and vendors.
This statement has been approved by the Management Committee of Greenberg Traurig, LLP on behalf of its members and is reviewed annually.