Anti-Slavery Policy

Anti-Slavery Policy

Policy Statement

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 and Human Trafficking

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:

  • Slavery – exercising powers of ownership over a person.
  • Servitude – where the obligation to provide services is imposed by the use of coercion.
  • Forced or compulsory labour – where work or services are exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily.
  • Human trafficking – arranging or facilitating the travel of another person with a view to their exploitation.

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.

Identifying Slavery or Human Trafficking

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:

  • The person may not be in possession of their own passport, identification or travel documents;
  • The person allowing others to speak for them even when spoken to directly;
  • The person is withdrawn or appears frightened;
  • The person does not seem to be able to freely contact friends or family;
  • The person has limited social interaction or contact with people outside their immediate environment.

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.

Responsibilities and Commitments

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.

Ashfords will:

  • Maintain clear policies and procedures preventing exploitation and human trafficking, protecting our colleagues, External Suppliers and our reputation;
  • Be clear about our own recruitment;
  • Check our supply chains;
  • Make appropriate checks on all employees, recruitment agencies, suppliers etc;
  • Not engage with any External Suppliers who have failed to provide satisfactory assurances with regard to their own approach to tackling modern slavery;
  • Have an open and transparent grievance procedure in place for all staff;
  • Make a clear, annual statement which will:
    • Show a summary of the steps we have taken during the financial year to ensure that slavery and human trafficking is not taking place in any part of the business or our supply chains.
    • Be published within 6 months of the end of each financial year.
    • Be built on each year and therefore show improvements can be and have been made.

Supervisors and line managers will:

  • Listen and be approachable to colleagues;
  • Respond appropriately if they are told something that might indicate a colleague is in an exploitive situation;
  • Remain alert to indicators of slavery;
  • Raise awareness by discussing issues and providing training;
  • Use their experience and professional judgement to gauge situations.

Colleagues will:

  • Follow the reporting procedure (see Reporting below) if there is any suspicion of a colleague or someone in our supply chain being controlled or forced by someone else to work or provide services;
  • Follow the reporting procedure (see Reporting below) if a colleague tells them something that may indicate they are or someone else is being exploited or ill-treated.


The principal areas of risk we face, related to slavery and human trafficking, include, but are not limited to, issues arising out of :

  • Supply chains
  • Outsourced activities
  • Cleaning and catering supplies
  • Corporate hospitality
  • Recruitment through agencies
  • General recruitment

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

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.

Recruitment using Agencies

Ashfords will only use reputable recruitment agencies. We will thoroughly check recruitment agencies before approving them. These checks will include:

  • A Supplier Questionnaire
  • Formal terms and conditions which include provisions on modern slavery and human trafficking are in place
  • Ensuring the staff an agency provides have the appropriate paperwork e.g. work visas

General Recruitment

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.

Reporting Procedure

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 Name:

Compliance Plan

Document Created/Revised:


Document Owner: Head of Risk & Compliance
Version No Date Reviewed/Authorised by
1.0 12/12/2019 Cary Whitmarsh
2.0 05/10/2021 Angharad Windless/Julie Wright
3.0 01/12/2022 Paul Brophy & Julie Wright