Ashfords is regulated by the Solicitors Regulation Authority. In order to comply with the SRA Standards and Regulations 2019, for this policy, we recognise the importance of Principle 1 (acting in a way that upholds the constitutional principle of the rule of law, and the proper administration of justice), Principle 2 (acting in a way that upholds public trust and confidence in the solicitors’ profession and in legal service provided by authorised persons), Principle 4 (acting with honesty), and Principle 5 (acting with integrity). We also ensure that we comply with Rule 1.2 and Rule 7.1 of the SRA Code of Conduct 2019 for Solicitors, RELs and RFLs, and that the Firm complies with Rule 1.2, Rule 2.1 and Rule 3.1 of the SRA Code of Conduct 2019 for Firms.
Ashfords does not tolerate the use of modern slavery or human trafficking anywhere within our organisation or in any of our supply chains.
Modern slavery is a crime resulting in despicable abuse of human rights. The Modern Slavery Act (MSA) 2015 consolidates slavery and trafficking offences. It covers four activities:
The MSA 2015 ensures that offences are subject to the toughest asset recovery regime under the Proceeds of Crime Act 2002. The National Crime Agency, the police and other law enforcement agencies have the power to bring to justice those engaged in human trafficking and slavery. Modern slavery is a complex and multi-faceted crime and tackling it requires all partners and staff to play a part. Protecting our workforce and reputation is vital. The MSA 2015 highlights the important need for businesses, and therefore the firm, to play a part in tackling slavery.
There is no typical victim of slavery or human trafficking and some victims do not understand that they have been exploited and are entitled to help and support. The following list of indicators, which is not exhaustive, could trigger suspicions that someone may be a slavery or trafficking victim:
A person may display a number of the indicators as set out above but they may not necessarily be a victim of slavery or trafficking.
All employees and members of Ashfords have a responsibility to ensure all colleagues and employees of External Suppliers are safeguarded, treated fairly and with dignity.
Supervisors and line managers will:
The principal areas of risk we face, related to slavery and human trafficking, include, but are not limited to, issues arising out of :
We acknowledge that any criminal behaviour that is identified as a result of our anti-money laundering procedures may also have a slavery and human trafficking consideration. We will ensure appropriate steps are taken in line with our reporting obligations under this policy.
Supply chains will be thoroughly checked to ensure the potential for slavery and human trafficking does not exist. This will be done by ensuring each step of the supply chain process is accounted for. We will establish who is providing goods and services to us and we will have mechanisms and processes in place to carry out due diligence on all external suppliers and conduct a risk assessment before engaging.
Companies with which we do business will be informed that Ashfords will not accept any form of exploitation.
Ashfords will only use reputable recruitment agencies. We will thoroughly check recruitment agencies before approving them. These checks will include:
Ashfords ensures that all staff have a written contract of employment and that they have not had to pay any direct or indirect fees to obtain work. We will ensure that all staff are legally able to work in the UK and we will check the names and addresses of our staff (a number of people listed at the same address may indicate high shared occupancy which is often related with those being exploited). We will provide all new recruits with information on their statutory rights, including sick pay, holiday pay and any other benefits they may be entitled to.
If, through the recruitment process, there is suspicion that someone is being exploited, the HR department will report their suspicions to Risk & Compliance.
We will continue to ensure that those people who are involved in procurement and recruitment roles receive training on a risk based basis, or as the need is identified. All employees are encouraged to identify and report any potential breaches of this policy.
Ashfords will monitor our procedures and review this policy at least annually on or following our publication of our annual statement. We will provide information and training, if necessary, on any changes which are made.
If the victim is in immediate danger – call 999
If the victim is not in immediate danger –
Be aware that not all victims want to be helped and there may be instances where reporting a suspected human trafficking case puts the potential victim at risk.
Step 1: Raise any concerns or suspicions as soon as possible with Risk & Compliance or the COLP.
Step 2: Risk & Compliance / COLP will decide a course of action and provide further guidance and advice.
This policy applies to all employees and members, locums and consultants of Ashfords and covers both our internal operations and our engagement with third parties including, but not limited to, suppliers.
“MSA” means Modern Slavery Act.
“External Suppliers” means suppliers and any other third parties we engage as a business.
|Document Owner: Head of Risk & Compliance|
|Version No||Date||Reviewed/Authorised by|
|2.0||05/10/2021||Angharad Windless/Julie Wright|
|3.0||01/12/2022||Paul Brophy & Julie Wright|