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Modern Slavery Act

Anti-slavery and trafficking policy

1. Policy Statement

1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

1.2 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

1.3 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

1.4 This policy does not form part of any employee’s contract of employment and we may amend it at any time.

2. Responsibility for the Policy

2.1 The Management Board has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

2.2 The Director of Human Resources has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

2.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

2.4 You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Director of Human Resources.

3. Compliance With the Policy

3.1 You must ensure that you read, understand and comply with this policy.

3.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

3.3 You must notify your manager or the Director of Human Resources as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.

3.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

3.5 If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or Director of Human Resources or report it in accordance with our Whistle Blowing Policy as soon as possible. You should note that where appropriate, and with the welfare and safety of local workers as a priority, we may give support and guidance to our suppliers to help them address coercive or exploitative work practices in their own business and supply chains.

3.6 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or Director of Human Resources.

3.7 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found at Grievance Procedure

4. Communication and Awareness of this Policy

4.1 Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary through the Brabners Academy.

4.2 Our commitment to addressing the issue of modern slavery in our business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

5. Breaches of this Policy

5.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

5.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.


Anti SLAVERY and trafficking STATEMENT

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 30th April 2016.

Modern Slavery encompasses slavery, servitude, human trafficking and forced labour. 

We have a zero tolerance policy towards modern slavery and human trafficking and are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business and to doing what we can to prevent our business from being used by human traffickers.

We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or the supply chain.

Brabners is Limited Liability Partnership under English Law and provides legal and consultancy services across the North West Region.  The Firm has 370 people and has a turnover of £29m for the financial year ending 2016.

Supply Chains

Each department will to a greater or lesser extent have supply chains on which it depends, and the interdependency of the various departments means that one supplier may have dealings with more than one department.

We will require companies who supply us, whether or not they are independently required to comply with the Act, to give us legally binding obligations (as and when contracts are entered into or renewed) to:

  • Comply with all applicable laws relating to slavery and human trafficking (including the Act)
  • Undertake their own due diligence into their own supply chains and business partners; and
  • Ensure that any contracts  with their subcontractors have similar obligations

We conduct due diligence on all suppliers before allowing them to work with the business. 

Our anti-slavery policy forms part of our contract with suppliers, we require that they confirm to us that:

  • They have taken steps to eradicate modern slavery within their business
  • They hold their own suppliers to account over modern slavery
  • (For UK based suppliers) They pay their employees at least the national minimum wage/national living wage (as appropriate)
  • (For international suppliers) They pay their employees any prevailing minimum wage application within their country of operation
  • We may terminate the contract at any time should any instances of modern slavery come to light.


We are currently reviewing the requirement to incorporate training into our Brabners Academy structure so that our people understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.

We will introduce new colleagues joining the firm to the Statement and Policy as part of their induction.

Our Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner.  These include:

·         Anti-Slavery Policy – This Policy sets out our stance on modern slavery and explains how employees can identify any instances of this and where they can go for help.

·         Recruitment Policy – We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced work against their will.

·         Whistle Blowing Policy – We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are treated or practices within our business or supply chain without fear of reprisals.

·         Our Business Values – this explains the manner in which we behave and what we stand for as an organisation and how we expect our employees and suppliers to act.

Our Performance Indicators

We will maintain a register of all concerns raised and the actions taken pertaining to slavery forced labour or human trafficking either within our own business or within our supply chains.

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

  • No reports are received from employees, the public or law enforcement agencies to indicate that modern slavery practices have been identified.

Approval for this Statement

This statement was approved by the Management Board on 4th July 2017

Name: Mark Brandwood

Position: Managing Partner

Date: 4th July 2017