Modern Slavery Statement

Background

In line with our purpose and guided by our values, our approach is to understand how and where modern slavery occurs and to continuously review and improve the policies and processes we have in place to prevent it. This expectation is set out in our Code of Business Conduct and reinforced in our Supplier Code of Conduct. 

The global Code of Business Conduct encourages colleagues to report, through our Speak Up policy, any actions that are unsafe, unethical, unlawful, or not in line with DWF Group policies. In practice, we are:

• Raising and maintaining employee education of the risks of modern slavery and human trafficking by continuously developing our training programmes.
• Implementing new processes, a revised approach to sustainable procurement and strengthening our supply chain assurance and due diligence.
• Collaborating across sectors to gain insight.
• Using our networks, including the UN Global Compact, to gain insight and raise awareness of these topics on a global scale. 

Governance

DWF supports the principles of Human Rights set out in the Universal Declaration of Human Rights (“the Declaration”), the International Labour Organisation (ILO) core labour standards.

Our ESG & Sustainability strategy is central to how we operate and ensure we are a responsible business. Our approach and how we manage risks in relation to; human rights, human trafficking, child and forced labour is overseen by our Executive Board.

We continue to make public commitments and disclose our approach to human rights, human trafficking, child and forced labour. We do this by reporting in line with the Global Reporting Initiative (GRI), Sustainability Accounting Standards Board (SASB), World Economic Forum Metrics, and UN Global Compact Communication on Progress. Furthermore, we have been accredited 'Silver' by EcoVadis.

Policies

Our Code of Business Conduct set out clear expectations, reinforced through the following policies available to all colleagues. These policies visibly reflect our commitment to responsible business policies and practices that are fair, transparent and inclusive and are those relevant to this statement:

• Anti-bribery & Corruption 
• Dignity at Work
• Diversity, Equity & Inclusion 
• ESG & Sustainability
• Human Rights
• Safeguarding
• Speak Up
• Sustainable Procurement

Our employment policies and pre-employment screening processes make sure that all our colleagues have the appropriate right to work and are employed in accordance with local employment legislation. 

Commitments

In the UK, we are accredited as a Living Wage Employer and our goal is to confidently state that 100% of DWF colleagues globally earn a living wage. 

We are committed to maintaining an open culture with the highest standards of honesty and accountability, a culture where colleagues can report any legitimate concerns in confidence via our Speak Up policy. We publicise and actively encourage use of the Speak up policy and we updated and refreshed our training in 2024 which is available to all DWF colleagues. This is mandatory during induction as part of our wider Conduct & Ethics training. 

The Code of Business Conduct reinforces our zero tolerance approach to:

• Unsafe, illegal or unethical working practices
• Discrimination, bullying and harassment
• Bribery and corruption
• Retaliation against anyone who speaks up and does the right thing

All DWF suppliers must implement a zero tolerance approach to human rights, human trafficking, child and/or forced labour and to comply with all local and national laws and regulations.

Supply chain

Our goal is to build trust and open relationships with our supply chain and work together to develop our approach to responsible sourcing and sustainable procurement. Expectations of suppliers is categorised into six key areas:

• Business Integrity
• Climate Action & Environmental Management
• Diversity & Inclusion 
• Health & Safety
• Human Rights
• Responsible Supply Chain Management

If there is a situation where a supplier may fall short within one of more of these areas, the Code requests that we must be notified immediately. We will work with the supplier on the development of an improvement plan. If the issue is serious enough or cannot be resolved in a reasonable period, we may review the provision of goods or services and ultimately discontinue the relationship.

Training and awareness

We continue to enhance our awareness to improve understanding of modern slavery so all our colleagues can support in the fight against it. Our training covers:

• The different types of criminal offences under the Modern Slavery Act
• The practical checks to be made when recruiting new colleagues
• How to identify victims of modern slavery
• The due diligence that needs to take place when working with clients and suppliers

Modern Slavery training now forms part of our mandatory learning as part of our Conduct & Ethics module that is applicable to all colleagues and new starters and learning needs revisiting once a year.

Stakeholder engagement

We continue to collaborate with our peers, supply chain, regulators, clients and external organisations to improve our approach to understanding the potential risk of modern slavery in our own supply chains and across the industry.

We recognise the importance of our stakeholder engagement and we are proud to be a signatory to the United Nations Global Compact (“UNGC”) and Women's Empowerment Principles. We have taken part in and provided a plan for Human Rights Due Diligence to the UNGC.

Code of Business Conduct

Our Business Code of Conducts outlines the principles and guidance to ensure our colleagues deliver on our purpose and help sustain a work environment that is open, inclusive and fair for all, keeping integrity at the heart of our culture.

Our Business Code of Conduct is published externally on our website.

Raising concerns

Our Speak Up policy outlines the process to raise a concern about wrongdoing, safe in the knowledge that we address investigations promptly and effectively and will be looked at on a case by case basis. An independent supplier manages our online and phone-based system, enabling colleagues to raise a concern about a genuine suspicion of malpractice or wrongdoing within the DWF Group or with any of our external stakeholders without receiving detrimental treatment including dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

Measuring effectiveness

We continue to review and report on the following indicators to assess the effectiveness of our actions:

Additional developments to support our actions in the last 12 months are:

• A better level of awareness on these topics for our colleagues including mandatory training
• A revised Code of Business Conduct
• A revised Supplier Code of Conduct 
• Improvements to our supplier assurance and due diligence processes
• Improved performance against recognised benchmarks 
• A new Sustainable Business & ESG advisory practice which can support our clients on these topics

Next steps

To improve on the quality and consistency of our risk assessment and decision-making to lead to more informed supplier acceptance we have undertaken an accelerator programme with UNGC on Human Rights out of which a plan of action for the most salient human rights concerns has been outlined. We will progress that plan which includes:

• Greater due diligence in our supply chain
• Understanding of the ability to Speak Up in our Supply Chain 
• Better assessment of our new Suppliers at the outset – including a new ESG Supplier Policy
• Greater commitments from our Suppliers 

The ESG Supplier Policy will follow a similar escalation process determined by the associated level of risk and corresponding business area lead. Additionally, we are planning a revised supplier assurance framework to help us to determine and assess any potential impacts of human rights, human trafficking, child and/or forced labour in our supply chain. 

Internal reviews of existing suppliers will be conducted at least quarterly depending on the associated level of risk. New suppliers will follow the ESG Supplier Policy prior to any agreement to work with the supplier and will follow our escalation process if necessary, to determine whether the supplier is right for our business. 

We will also focus on working closer with our suppliers to collaborate on education and training and continue to identify opportunities to deliver positive outcomes with our colleagues, clients and communities. 

Sir Nigel Knowles
Group CEO and director of Aquila Topco Limited and designated member of DWF Law LLP and DWF LLP
29 October 2024

The Directors of Aquila Topco Limited approved this statement on 29 October 2024. The Designated Members of DWF Law LLP and DWF LLP approved this statement on 23 October 2024. 

DWF is a collective trading name for Aquila Topco Limited and all of its subsidiaries and subsidiary undertakings (as defined in the UK's Companies Act 2006) including DWF Law LLP, DWF LLP and all incorporated associations without legal personality.