ABOUT US EXPERTISE INTERNATIONAL PEOPLE CAREERS NEWS & PUBLICATIONS CONTACT US Home » Modern slavery and human trafficking statement MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT This statement is made on behalf of Penningtons Manches Cooper LLP pursuant to section 54(1) of the Modern Slavery Act 2015 (the Act) for the financial year ending 31 March 2021. Penningtons Manches Cooper is a limited liability partnership registered in England and Wales (registered number OC311575) and has the following subsidiaries: Penningtons Manches Cooper Singapore LLP and Bateson, Vitta & Anassis Law Firm trading as Penningtons Manches Cooper Greece. More information about the firm can be found on our website, penningtonslaw.com. As an international law firm, Penningtons Manches Cooper is committed to practices that respect human rights in all of our business dealings and relationships. We take steps to ensure that slavery and human trafficking does not occur within our business or supply chain. Penningtons Manches Cooper is a professional service firm which is regulated by the Solicitors Regulatory Authority; we therefore consider the risk of modern slavery occurring within our business to be low. Approach Our policies reflect our zero tolerance approach to slavery and human trafficking. Our whistleblowing policy promotes the reporting of modern slavery concerns and provides protection for any employees that do so. Employees are informed of the policy at induction and the policy is accessible to staff at any time via our intranet. Penningtons Manches Cooper is committed to ensuring that all of our people, including onsite contractors, are paid fairly for the work that they do. As part of this, we continue to be accredited as a “Living Wage” employer in the UK which means that anyone who is employed by the firm is at least paid the real living wage. We expect our outsourced providers to do the same. We comply with relevant employment legislation across all of our offices and our recruitment due diligence process ensures that all of our people have a right to work in the countries where we have offices/they are based. We only work with recruitment agencies that confirm that they are compliant with the requirements of the Act. We expect our suppliers to comply with the relevant legislation for their business and our procurement process includes verification of their compliance programmes. Checks on relevant suppliers on contract renewal aimed at detecting slavery, servitude, forced labour or human trafficking in our supply chain are also completed. Such checks are conducted by those overseeing procurement who will work alongside the best practice team. Where concerns arise, the best practice team will be informed and will take appropriate action. Our partners and employees are required to complete an e-learning module that sets out the impact of modern slavery and the part we all play in its prevention. This training is provided at induction stage and repeated every two years. The Penningtons Manches Cooper Foundation has a particular focus on vulnerable people including the homeless and victims of slavery and human trafficking. Our partners and employees are encouraged to take an active role in supporting the aims of the foundation, from fundraising to volunteering. Our ongoing commitment Our commitment to ensure that slavery and human trafficking does not occur in our supply chain remains a priority during our 2021/22 financial year. Action includes an audit of cleaning suppliers, which uncovered no concerns, and, following the merger with Thomas Cooper in 2019, we have successfully integrated our technical systems internationally despite the unexpected challenges of the pandemic and suppression of international travel. These consistent technical systems now provide a good platform in which to continue our work throughout 2021/22 when we intend to place more focus on worldwide procurement, having identified this as a potential higher risk area. In addition to this, we will be conducting another round of training on the requirements of the Act to ensure continued awareness and vigilance. We will also continue to develop our procurement processes to ensure that they are robust. This statement has been approved by the firm’s management. 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