Modern Slavery and Human Trafficking Statement (FY 2023)

Introduction from Chair and Chief Executive Officer

Every day we have to advise our clients on their responsibilities, their rights, their ethical and professional obligations, and the consequences of getting them wrong. We take the same approach with our own business and try to hold ourselves to the highest standards.

As one of the world’s leading law firms, we have a responsibility to uphold and champion the rule of law and its underlying principles. We support the UK Government's objective of eradicating modern slavery and human trafficking in all its forms, and are committed to ensure that human rights abuses, however they may arise, are recognised and eradicated in our business and supply chains.

Marie-Aimée de Dampierre Chair	Miguel Zaldivar CEO

For the purposes of this statement, the term 'modern slavery' encapsulates slavery, servitude, forced or compulsory labour, and human trafficking (that is to say, the practice of illegally transporting someone from one area or country to another, usually for the purposes of being exploited).

Our business, organisational structure and supply chains

Hogan Lovells International LLP, Hogan Lovells (Paris) LLP and Hogan Lovells Services are part of Hogan Lovells, an international legal practice that works with corporations, financial institutions, governments, and social enterprises across the spectrum of their business and legal issues both globally and locally. We have in excess of 6,000 people working from offices in Africa, Asia, Europe, Latin America, the Middle East, and the United States. For further information about our organisation, please see the 'About Us' section at www.hoganlovells.com.

Our business is office-based and our primary supply chain categories support those office operations. Supply categories include office space, office services (including the provision of security, catering, office supplies and cleaning), IT and technology, professional services, and business travel. There are more than 2,000 first tier (i.e. direct) suppliers in our supply chain.

Policies and commitments

Hogan Lovells are committed to the highest standards of ethical, moral and legal business conduct and we expect our suppliers to uphold the same values. We have adopted a modern slavery policy which prohibits modern slavery in our business and supply chains, and are committed to implementing systems and controls aimed at ensuring that modern slavery is recognised and eradicated.

We have a human rights policy which confirms that we respect and support international human rights, including the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, and the International Covenant on Economic, Social and Cultural Rights. Hogan Lovells are a signatory to the UN Global Compact and we produce an annual Communication on Progress setting out how its principles are integrated across our organisation, including principles one ('the protection of internationally proclaimed human rights') and four ('the elimination of all forms of forced and compulsory labour').

In addition to being a member of the UN Global Compact, Hogan Lovells have endorsed the UN Guiding Principles on Business and Human Rights. We respect human rights and implement that through our management policies and processes and by providing education and training for our people. We also support the UN Sustainable Development Goals. For further information about our policies, please see the ‘Responsible Business’ section at www.hoganlovells.com.

Initiatives in London

We have a strong and historic commitment to acting for victims trafficking through our pro bono practice.  We act for over 70 survivors annually in partnership with Victim Support and the Salvation Army to secure reparations and accountability of perpetrators nationally and internationally (see Bringing perpetrators of human trafficking to account). We also work with former UK Anti-Slavery Commissioners Dame Sara Thornton and Kevin Hyland OBE on policy reform to address modern day slavery issues.

We are voluntary signatories to the London Living Wage (LLW). This campaign provides a benchmark for employers who choose to pay their employees at a rate which is calculated according to the cost of living. We pay our employees at a rate higher than the LLW, but we also require our contract staff providers, such as caterers, to pay their own employees the LLW rate as a minimum.

Modern slavery risks and steps to eliminate

We have a dedicated core group addressing risks in the area of modern slavery and ensuring that appropriate measures are applied to assess, manage and minimise risk. This group comprises representatives from compliance, procurement and our human rights practice.

As a regulated provider of legal services and employer of predominantly professionally qualified and highly skilled people, the risk of modern slavery within our business is considered low. We apply robust policies and procedures concerning employment screening (including work eligibility checks) and employment conditions (including our LLW commitments).

As noted above, the majority of our suppliers supply standard office goods or services. We recognise there are supplies involving potentially higher risk (for example, supplies of food and drink and promotional products) and some services involving relatively high levels of contracted labour. We have a global database for all our supplier contracts which provides increased control and coordination.

Suppliers are risk assessed and categorised considering the nature of their business as well as country of operation, and product and industry characteristics. Suppliers categorised as presenting significant risk of modern slavery are subject to additional due diligence, primarily based on public sources of information including checks of their own modern slavery and human trafficking statements where applicable, and any other published policies and procedures. Where, following additional due diligence and checks, a supplier is still assessed as presenting a significant risk of modern slavery or failing to meet our standards, they are required to complete a modern slavery questionnaire. The quality and transparency of responses to these questionnaires is assessed.

This risk assessment exercise has been completed in respect of suppliers to all our offices. To date, we have not identified any occurrence of modern slavery in our supply chain, nor have we identified any risks of modern slavery that we have not been able to resolve through additional due diligence or engagement with the supplier.

We have developed a global Supplier Code of Conduct which applies to our providers of goods and services and sets out the standards we expect them to observe, including in respect of modern slavery. Where our standards are not met, suppliers are expected to take and evidence remedial steps to ensure their activities in our supply chain are free from modern slavery, timely considering what approach will result in the safest outcome for potential victims and enhance supplier behaviour.

We have adopted a master services agreement used for the purchase of services which addresses our requirements for suppliers around modern slavery. We have implemented standard contract review guidelines to be used when using supplier contractual documentation, which outline the acceptable terms and conditions for the firm’s contracts and includes guidance specific to modern slavery.

We have implemented a Contract Authorisation and Signature Policy that sets out the internal governance procedure for approving financial transactions and signing supplier contracts. The policy ensures appropriate checks and balances for review and authorisation by senior and qualified personnel.

Education and training

We have developed training programmes to provide the skill and knowledge to those staff responsible for procurement to recognise the key issues and risks and how these must be addressed. This training has been undertaken by key personnel in our UK offices and by office managers in our other international offices, who are generally responsible for contracts and relationships with suppliers. We are committed to promoting and maximising awareness of modern slavery risks across our organisation, and an online education module on human rights is available to all staff regardless of their role.

In order to detect any modern slavery in our business or supply chains any concerns are to  be reported without delay or fear of detrimental treatment. Our modern slavery policy requires anyone who becomes aware of, or suspects modern slavery in our business or supply chains to report it to the firm's General Counsel or, if they wish to report anonymously, they may do so as set out in the firm's global whistleblowing policy.

Current and future initiatives

In October 2022, we adopted a Responsible Procurement Policy. It requires all firm personnel engaged in procurement to respect internationally recognised human rights, to identify any signs of modern slavery within our supply chain, and to eliminate the use of products and services associated with modern slavery.

The continued development of global policies and standardised processes for procurement activities will inform the sourcing and management of our third-party suppliers. All procurement policies are subject to periodic review. The policies align to the UN Sustainable Development Goals and those of our core business at Hogan Lovells, including with respect to modern slavery.

Further enhancement of our supplier risk assessment process is in development, which will further inform our efforts to monitor and action corrective steps as needed. Recent development of our new contract management system provides workspaces enabling us to document vendor and contract key performance indicators (KPIs).

Our core group continues to collaborate and evolve our efforts to assess, manage and minimise risks associated with modern slavery.

Board approval

This statement has been approved by the board of Hogan Lovells International LLP on behalf of its members, by the members of Hogan Lovells (Paris) LLP, and by the board of directors of Hogan Lovells Services. 

Marie-Aimée de Dampierre, designated member, on behalf of Hogan Lovells International LLP

Penny Angell, director, on behalf of Hogan Lovells Services

Penny Angell, member of Hogan Lovells International LLP as member, on behalf  of Hogan Lovells (Paris) LLP