UK Modern Slavery Act Statement
Buckley Sandler LLP (“Buckley Sandler” or the “Firm”) is pleased to issue this modern slavery and human trafficking statement in compliance with Section 54 of the United Kingdom’s Modern Slavery Act 2015 and to reflect the Firm’s support of human rights worldwide. The statement is issued for the Firm fiscal year that ended December 31, 2017. Although subject to review annually, the statement will also apply to subsequent fiscal years unless and until withdrawn, superseded, or modified by the Firm.
Buckley Sandler is a limited liability partnership organized under the laws of the District of Columbia, USA. The Firm is engaged in the practice of United States law. Its partners and employees include more than 150 lawyers licensed by various US jurisdictions. The Firm’s US offices are located in Washington, DC, Los Angeles, CA, San Francisco, CA, New York, NY, and Chicago, IL. The Firm also has a UK office located in London. The Firm offers premier enforcement, litigation, compliance, regulatory, and transactional legal services everywhere money moves. Our clients include financial services institutions and financial technology companies, other leading companies and joint ventures, private equity funds, and individuals throughout the world.
The Firm’s supply chain consists primarily of suppliers of professional and office services and office goods. The Firm’s professional services suppliers include, for example, accountants, information technology professionals, marketing professionals, travel agents, other lawyers, and consultants in various fields. The Firm’s office services suppliers include, for example, office and document managers, delivery services, and catering, maintenance, repair, and cleaning services. The Firm’s suppliers of office goods include various retailers and wholesalers. The goods purchased or leased from these suppliers include, for example, books, publications, research databases, computer hardware and software, copiers, telephones, other office equipment, office furniture and fixtures, office supplies, and related goods.
Modern Slavery and Human Trafficking Risks
The Firm believes that the risks of modern slavery and human trafficking practices within its business are very low. The Firm’s business is a sophisticated legal practice that does not involve and is not built upon the type of low skilled labor often associated with such practices. Rather, the Firm’s end product is skilled legal advice, advocacy, and services generated by highly trained lawyers. Moreover, these lawyers are licensed professionals who have sworn an oath to comply with the law and are subject to a comprehensive and enforceable set of ethical rules.
The Firm also believes that the risks of modern slavery and human trafficking violations within its supply chain are very low. The Firm’s professional service suppliers provide sophisticated and often bespoke professional advice and services. These services also do not use or depend on low skilled labor. The Firm’s office services suppliers are engaged in a range of activities, from higher skilled to lower skilled, but almost all are engaged in services conducted in close proximity to or in close cooperation with Firm personnel. Consequently, these services are conducted in a professional environment where exploitive practices would be difficult if not impossible to hide. The Firm’s suppliers of office goods are reputable retailers and wholesalers. The Firm does not contract with source suppliers in industries or regions of the world where the risks of modern slavery and human trafficking are relatively high.
Policy, Detection, and Deterrence
Despite the very low risks of modern slavery and human trafficking practices within its business and supply chain, the Firm has adopted a supplier policy that, among other things, is designed to raise awareness about the evils of such practices and to help detect and deter them. In this regard, the policy provides that the Firm will not knowingly do business with a prospective or current supplier that engages in modern slavery or human trafficking practices. The policy also reminds lawyers and other personnel to remain vigilant about such practices and to report promptly to Firm management any prospective or current supplier known to engage in or suspected of such practices. The policy is included in the Firm Handbook accessible to all Firm lawyers and other personnel. In addition, the policy has been incorporated into the policy and compliance training conducted for all new Firm lawyers and personnel.
The Firm has also instructed its primary buyers of goods and services to promote compliance with the Firm’s supplier policy, including its prohibition on modern slavery and human trafficking practices, in their dealings with prospective and current suppliers. The buyers have been instructed to take various actions as appropriate toward this end. These may include, for example, due diligence on prospective and current suppliers with regard to modern slavery and human trafficking issues and the termination of negotiations or contracts if concerns are identified. They may also include, as a further example, the insertion of legal compliance clauses in supplier contracts and the ongoing monitoring of performance under such clauses.
On behalf of the Firm, the undersigned Co-Managing Partners of the Firm have approved and issued the foregoing statement as of the 12th day of January 2018 and have instructed that it be posted on the Firm’s website.
Benjamin B. Klubes and John P. Kromer