Modern Slavery and Human Trafficking Statement

This statement is published on behalf of Hogan Lovells International LLP and Hogan Lovells Services pursuant to section 54 of the UK Modern Slavery Act 2015. It constitutes our modern slavery and human trafficking statement for the financial year ending 31 December 2017.

Introduction from Chair and Chief Executive Officer

Every day we have to advise our clients on their responsibilities, their rights, their ethical and professional obligations, and the consequences of getting them wrong. We take the same approach with our own business and try to hold ourselves to the highest standards.

As one of the world’s leading law firms, operating from 51 offices across six continents, we have a responsibility to uphold and champion the rule of law and its underlying principles. We support the UK Government's objective of eradicating modern slavery and human trafficking in all its forms, and are committed to ensure that human rights abuses, however they may arise, are recognised and eradicated in our business and supply chains.

       
Leopold von Gerlach electronic signature      Stephen J. Immelt 
Leopold von Gerlach
Chair, Hogan Lovells
    Stephen J. Immelt
CEO, Hogan Lovells

For the purposes of this statement, the term 'modern slavery' encapsulates slavery, servitude, forced or compulsory labour and human trafficking.

Our business, organisational structure and supply chains

Hogan Lovells International LLP and Hogan Lovells Services are part of Hogan Lovells, an international legal practice that works with corporations, financial institutions, governments, and social enterprises across the spectrum of their business and legal issues both globally and locally. We have in excess of 6,000 people working from 51 offices in Africa, Asia, Europe, Latin America, the Middle East, and the United States. For further information about our organisation, please see About Us.

Our business is office-based and our primary supply chain categories support these office operations. Supply categories include office space, office services (including the provision of security, catering office supplies and cleaning), IT and technology, professional services, and business travel. There are more than 1,000 first tier (i.e. direct) suppliers in our supply chain.

Policies and commitments

Hogan Lovells is committed to the highest ethical standards in the conduct of its business worldwide and we expect our suppliers to uphold the same values. We will not tolerate modern slavery in our business or supply chains and take effective steps to meet this commitment.

In 2017, we adopted a human rights policy confirming that we respect and support international human rights, including the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights.

We are signatories to the UN Global Compact and produce an annual Communication on Progress setting out how its principals are integrated across our organisation, including principles one ('the protection of internationally proclaimed human rights') and four ('the elimination of all forms of forced and compulsory labour').

In addition to being member of the UN Global Compact, we have endorsed the UN Guiding Principles on Business and Human Rights. We respect human rights and implement that through our management policies and processes and by providing education and training for our people. We also support the Sustainable Development Goals.

We sit on the Advisory Panel to the UK's Anti-Slavery Commissioner and perform voluntary legal work in support of their aims. We also have a partnership with London’s Metropolitan Police and various other charities to support victims of forced prostitution and labour, and have recovered substantial compensation for victims.

We are voluntary signatories to London Living Wage (LLW). This campaign provides a benchmark for employers who choose to pay their employees at a rate which is calculated according to the cost of living. We pay our employees at a rate higher than the LLW, but we also require our contract staff providers, such as caterers, to pay their own employees the LLW rate as a minimum.

Modern slavery risks and steps to eliminate

We have a dedicated core group addressing risks in the area of modern slavery and ensuring that appropriate measures are applied to assess, manage and minimise risk. This group comprises representatives from compliance, procurement and our human rights practice. It is comprised of lawyers and senior managers.

As a regulated provider of legal services and employer of predominantly professionally qualified and highly skilled people, the risk of modern slavery within our business is considered low. We apply robust policies and procedures concerning employment screening (including work eligibility checks) and employment conditions (including our LLW commitments).

The majority of our suppliers are UK-based and supply standard goods or services. We do not simply buy goods or services on cost based principles. We recognise there are areas of potentially higher risk and some services involving relatively high levels of contracted labour. We have a database of our first tier suppliers to maximise control and coordination.

Suppliers are risk assessed and categorised taking into account the nature of their business as well as country of operation, and product and industry characteristics. Suppliers categorised as presenting significant risk of modern slavery are subject to additional due diligence, primarily based on public sources of information including checks of their own modern slavery and human trafficking statements where applicable, and any other published policies and procedures. Where, following additional due diligence and checks, a supplier is still assessed as presenting a significant risk of modern slavery or failing to meet our standards, they are required to complete a modern slavery questionnaire. The quality and transparency of responses to these questionnaires is assessed.

This risk assessment exercise has been completed in respect of suppliers to our London office, and is in the process of being completed in respect of suppliers to other offices. 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 have developed a Supplier Code of Conduct which applies to our providers of goods and services and sets out the standards we expect them to observe, including in respect of modern slavery risks. Where our standards are not met, suppliers are expected to take and evidence remedial steps to ensure their activities in our supply chain are free from modern slavery, timely considering what approach will result in the safest outcome for potential victims and enhance supplier behaviour.

Education and training

We have developed training and information forums to provide the skill and knowledge to those staff responsible for procurement to recognise the key issues and risks and how these must be addressed. We are committed to promoting and maximising awareness of modern slavery risks across our organisation, and an online education module on human rights is available to all staff regardless of their role.

In order to detect any modern slavery in our business or supply chains we must encourage any concerns to be reported without delay or fear of detrimental treatment. We will soon adopt a new whistleblowing policy which provides access to an external and anonymous reporting hotline.

Next steps

We will continue to review and develop our supply chain due diligence and risk assessment across our offices to ensure a robust and consistent approach to supply chain risks. We will continue to make all efforts to identify any significant risks in our business and supply chain and implement any actions appropriate or necessary directly with suppliers.

We are about to commence an audit programme that will review the effectiveness of the measures we have taken to recognise and eradicate modern slavery from our business and supply chains.

Board approval

This statement has been approved by the board of Hogan Lovells International LLP and by the board of directors of Hogan Lovells Services.

 

Leopold von Gerlach electronic signature

Leopold von Gerlach, designated member, on behalf of Hogan Lovells International LLP
27 June 2018

Susan Bright's signature

Susan Bright, director, on behalf of Hogan Lovells Services
28 June 2018

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