Modern Slavery

The Firm

Rainer Hughes is committed to all legal compliances and ethical business practice; this also includes improving our practices to combat modern day Slavery and Human Trafficking. We also choose to work with suppliers and contractors who we believe share the same commitment.

Risk Assessment

As a professional service with international recognition and a Lexcel credited Legal 500 firm, we have adopted a globally applicable Ethics Policy in January 2020 (reviewed and restated every year), we strongly believe that we are at low risk of modern slavery occurring within our business. However, we remain alert for the occurrence of the same, and our policy and reporting requirements cover our approach to this. There is a greater risk in our supply chain which comprises of non-regulated businesses.

Policy on slavery and human trafficking

Rainer Hughes is committed to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery and Human Trafficking Policy reflects our commitment to use only legal and ethical business practices. We have implemented and enforced effective systems and controls to ensure modern slavery and human trafficking is not taking place within the firm or anywhere in the supply chain.

Training

To ensure that the firm has a high level of understanding of the risks of modern slavery and human trafficking in our firm, we have procured adequate training resources for our staff with direct contact and responsibility for procurement within the firm. The training is undertaken by those with direct procurement responsibilities.

Accountability

We have a zero-tolerance policy against modern slavery and human trafficking, and require all our partners, employees, officers, and consultants of the firm, including temporary and contracted workers and others who are subject to direction of the firm to comply with our Anti-slavery and Human Trafficking Policies. As with all alleged violations of policy, we investigate issues and take appropriate action up to and including termination of employment and termination of agreements for suppliers and contractors.

Progress

Rainer Hughes has a system in place to comply by the law and ensure there’s consistent due diligence on suppliers across a range of issues including Modern Slavery compliance. The system in place is based on a risk analysis by sector and spend. Nonconformities are flagged and red-listed.

All the relevant departments ensure that the right people undertake our anti-modern slavery training, including relevant new staff.

We will continue to keep improving our procurement process in Shenfield, greater oversight of spending, allowing more scrutiny of potentially higher risk suppliers.

Next steps:

We will:

• Continue with our proactive approach to sustain measures against Modern Slavery compliance and measure its effectiveness and identify gaps, if any.
• Make further improvements to our supplier screening process and risk-based assessments of suppliers.
• Expand the knowledge on modern day slavery and trafficking, increasing awareness and compliance in our ongoing operational risk review process. The outcomes of the Operational Review process will be reviewed, helping us identify the gaps (if any) and where practice can be improved.