This statement is made pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 on behalf of Northcroft LAW (the Law Firm) and all of its group companies, entities, branches, offices, and/or affiliates (the “Group”, or “we”). The Law Firm is a controlling party within the Group.
The statement sets out the steps the Group has taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business. The Law Firm’s financial year ends on the 31^st of December, and this constitutes our slavery and human trafficking statement for the 2021 financial year.

CEO’s statement

We recognise the suffering which modern slavery and human trafficking causes. In an increasingly global marketplace, we recognise that all businesses have a responsibility to understand whether modern slavery and human trafficking is taking place within their supply chains, and this is a responsibility we take seriously.

Our organisation

The Northcroft LAW name a Northcroft LAW™ trademark created and established under and operated by Northcrofts (ME) LTD, a company incorporated under the laws of Turks and Caicos, British West Indies, with registration number E.7210, whose registered office and principal place of business is at PO Box 25 Britannic House, Providenciales, Turks and Caicos, British West Indies, a company that provides international legal services and license the Northcroft LAW™ trademark to other territories.
We provide a full range of legal services and multi purposed consultancies to clients in the corporate, business, construction and various other sectors, including but not limited to telecommunications, energy, financial institutions, real estate development, banking & finance, global private services, hotels & leisure, insurance, life sciences and healthcare, manufacturing, private equity, franchises, Joint Ventures, mergers and acquisitions, technology, media, transportation, infrastructure, oil & gas, retail, venture technology and emerging market growth.
Northcroft LAW, a global legal practice providing client services locally and/or internationally through our worldwide interconnected multinational network of member firms offices, branches, subsidiaries, partners and/or affiliates.
Our supply chains include leases for the properties we occupy, catering and cleaning services, some outsourced business process services, recruitment and employment agencies and the purchase of goods including office furniture and supplies and IT software and equipment.
As a law firm, we always work to the highest professional standards and comply with all laws, regulations and rules relevant to our business. 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 business partners.

Our policies on slavery & human trafficking

The Group is committed to ensuring we are not supplied by anyone who engages in human trafficking and modern slavery. Please see our Anti-Slavery Policy.
Compliance with laws regarding eradication of human trafficking and slavery is embedded Northcroft LAW’s Global Code of Ethics and Conduct and Northcroft LAW’s Commitment to Rule of Law and Human Rights.
The Anti-Slavery Policy has been recommended and approved by our management, and ultimately the Chief Executive Officer. A team led by our Chief Legal Officer implements the Policy, working closely with all relevant divisions, support teams, partners, branches, offices, and affiliates within the Group, including Human Resources, Finance, Facilities, Compliance and IT, to implements the Policy.
The Law Firm’s Country and Office Managing Partners are responsible for ensuring compliance with the Anti-Slavery Policy locally.
We also have a Whistleblowing Policy, which is published on our intranet site. If employees have concerns about any wrongdoing or breaches of law, they can raise these concerns in confidence without fear of disciplinary action.
In 2021, our Chief Executive Officer formed the Sustainability and Governance Committee, which focuses on issues of corporate social responsibility, including environmental issues and human rights.

Our Input

Our working practices respect and uphold human rights for our partners, employees and contractors. We fully comply with the United Nations Global Compact and confirm our commitment to its ten principles, including among others elimination of all forms of forced and compulsory labour and effective abolition of child labour.
We take the following steps to identify risks of modern slavery and human trafficking within our business and our supply chain:
We assess risk related to human trafficking and forced labour associated with our supply base and we are dedicated to continuing our ongoing internal process in identifying such risks.
Our preliminary assessments will be based upon geography, the product or services being purchased, supplier quality performance and the nature of the business transaction.
We are planning carry out a due diligence on relevant and appropriate suppliers by asking for information about their policies on fair sourcing of goods and services, and employment practices. In respect of certain suppliers, we seek the right to request and receive copies of their policies.
In 2021 we have adopted a Supplier Code of Ethical Business Practices, which we share with all relevant and appropriate suppliers and which we expect our key suppliers to adhere to. The code sets out the standards we expect our suppliers to uphold at all times relating to various matters including but not limited to anti-bribery and corruption, human trafficking, slavery, and ethical behaviour.
We ask our key regional suppliers to comply with our Supplier Code of Ethical Business Practices and uphold its principles in their own supply chains. The right to audit our suppliers is included in our Supplier Code of Ethical Business Practices.
We are working on a mandatory training programme for the purpose of combating modern slavery and human trafficking for all staff as part of our induction training. Training requirements on modern slavery will be kept under review for those staff members working in human resources and procurement and we are in the process of reviewing our procurement guidelines to appropriately reflect our commitments to human rights, including eradication of modern slavery and human trafficking.
We will periodically review the effectiveness of the implemented measures and make such changes as may be required for ensuring that slavery and human trafficking are not taking place in our supply chains or in any part of our business and we will implement on an ongoing basis a refresher training programme to all staff on their obligations under the Modern Slavery Act 2015 to supplement our induction training programme.
We will seek to impose contractual terms on relevant and appropriate suppliers asking them to warrant that they and their suppliers are in full compliance with our Anti-Slavery Policy. We will seek to audit our suppliers where there is deemed to be considerable risk or might have any concerns of non-compliance to ensure that this is the case. The right to audit will now be included in our code of ethical business practices.

Approval

This statement has been approved for and on behalf of the members of Northcroft LAW Group & Affiliates.