Introduction
This statement sets out Fletchers Group’s actions to understand all potential modern slavery risks related to our business and to ensure that there is no slavery or human trafficking in our business and our supply chains. This statement relates to actions and activities during the financial year 1 May 2022 to 30 April 2023.
Reflecting one of our three values, The Power of our People, we are absolutely committed to preventing slavery and human trafficking in all of our corporate activities, and to ensuring that our supply chains are free from slavery and human trafficking. Corporate social responsibility is an intrinsic part of our culture, and we aim to make a lasting and positive impact on the communities in which we live and work. We expect the same from our suppliers and partner organisations.
Our company
Fletchers Group owns and operates some of the highest rated personal injury and medical negligence teams in the UK. We are listed as a Top 100 UK Law Firm specialising in complex personal injury, medical negligence, motorcycle accident, cycling incidents, and any accident that results in serious, life-changing injuries. Within the Group portfolio are Fletchers Solicitors, Patient Claim Line, Minton Morrill, Cycle-SOS and Biker-SOS.
We currently only operate in England and Wales.
We do not currently undertake any activities that are considered to be at high risk of slavery or human trafficking.
Responsibility for our anti-slavery initiatives is as follows:
- Values: The Executive Leadership Team are responsible for setting, communicating and modelling our values as a company
- Training: The People team is responsible for developing suitable training for colleagues across the company
- Policies:The People team is responsible for developing and reviewing policies which are supported and agreed by the Executive Leadership Team.
- Risk assessments: Broad organisational responsibility for human rights and modern slavery risk analysis is shared between the People team (for recruitment, employment and other People-based activities) and the Compliance team (for legal activities).
- Investigations/due diligence:The People team will be responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking, and for making recommendations for action should any be identified.
- Communications: With support from the Marketing team, the People and Compliance teams will lead on ensuring our stance on modern slavery and human trafficking is understood by all of our colleagues
Due diligence
We undertake due diligence when considering taking on new suppliers, and regularly review our existing suppliers. Our due diligence and reviews include:
- evaluating the modern slavery and human trafficking risks of each new supplier;
- taking steps to improve substandard suppliers’ practices; and
- invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.
Training
We make the UK Home Office’s “Modern Slavery Awareness & Victim Identification Guidance” document available to all people managers and have required all of our People team to read it.
During the period covered by this policy, we will require all HR professionals in our People team, as well as our CSR Manager, to complete training on modern slavery as a module within our Learning Management System.
Our modern slavery training covers:
- how to identify the signs of slavery and human trafficking;
- what initial steps should be taken if slavery or human trafficking is suspected;
- how to escalate potential slavery or human trafficking issues;
- how to assess the risk of slavery and human trafficking in relation to various aspects of the business;
what external help is available.
Awareness-raising programme
We will regularly raise awareness of modern slavery issues by distributing information to colleagues through our Yammer platform.
The posts will explain to colleagues:
- the basic principles of the Modern Slavery Act 2015;
- how employers can identify and prevent slavery and human trafficking;
- what colleagues can do to flag up potential slavery or human trafficking issues to the relevant parties within our organisation; and
- what external help is available, for example through the Modern Slavery Helpline.
Relevant policies
We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
- Whistleblowing policy We encourage all our colleagues, clients and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Colleagues, clients or others who have any concerns can email whistleblowing@fs.co.uk.
- Colleague code of conduct Our code makes clear to colleagues the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of colleague conduct and ethical behaviour.
- Supplier code of conduct We are committed to ensuring that our suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. Serious violations of our supplier code of conduct will lead to the termination of the business relationship.
- Recruitment/Agency workers policy We use only specified, reputable employment agencies to source labour and always verify the practices of any new agency before accepting workers from that agency.
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