Anti-slavery statement
This statement relates to the actions and activities of TLT LLP and TLT NI LLP (‘TLT’) during the financial year 2019/2020 (1 May 2019 - 30 April 2020).
This statement is made by TLT on 27 April 2020 and applies to all individuals working for or on behalf of TLT in any capacity, including all employees, partners, contractors, external consultants, third-party representatives and business partners, regardless of where they are operating.
The statement was approved by the Executive Board of the Firm.
TLT is committed to the prevention of the use of forced labour and has a zero tolerance policy against human trafficking and slavery.
TLT is committed to acting ethically and with integrity in all our business dealings and relationships.
This includes implementing and enforcing effective systems and controls to ensure slavery is not taking place anywhere in our business or in any of our supply chains.
TLT's structure
TLT LLP and TLT NI LLP operate as limited liability partnerships registered in England and Wales and Northern Ireland, with over 1,000 employees and partners across 6 UK offices and a niche team in Piraeus.
Our supply chain consists of goods and services procured to enable the Firm to deliver its services.
Our relationships with suppliers and their employees, business partners, agents and others working on their behalf (collectively "Third Parties") principally include professional services and consultancy, property, facilities management, human resources, information technology and marketing.
Our approach
TLT is committed to the highest ethical standards. We have introduced a number of policies that support our commitment to preventing acts of slavery and human trafficking.
All policies are reviewed at least annually to ensure continued compliance with the Modern Slavery Act 2015.
Our policies
- Anti-slavery Policy – ensuring that TLT LLP and TLT NI LLP maintain compliance with the Modern Slavery Act 2015. We expect the same standard of conduct from the firm's contractors and third-party service providers in all dealings on our behalf;
- Data Breach Management Policy – ensuring that all individuals have a mechanism for reporting breaches of Firm policies and procedures, and errors, acts or omissions which result in breach of the legal or regulatory obligations of individuals or the Firm;
- Procurement and Supplier Management Policy – ensuring suitable vetting of our supply chain and an on-going review of all our suppliers;
- Corporate Social Responsibility Policy – ensuring that TLT LLP and TLT NI LLP operate in a responsible way, making a positive impact on the local and national communities;
- Recruitment Policy and Screening and Vetting Policy – ensuring that all individuals employed by TLT LLP and TLT NI LLP are appropriately vetted and have the right to work in the UK;
- Whistleblowing Policy – ensuring fair process and protection for whistle blowers. TLT encourages all of its employees to report any concerns related to the activities of the Firm. The Firm's whistleblowing procedure is designed to ensure that any matter raised under this procedure will be investigated thoroughly, promptly and confidentially, and the outcome of the investigation reported back to the individual who raised the issue.
Our training
We invest in educating our employees to recognise the risks of slavery and human trafficking in our business and supply chain.
We provide mandatory modern slavery e-learning for all new starters and mandatory annual refresher training for all staff.
We maintain a live database of all policies, which employees can readily access on the Firm’s intranet.
Supply chain due diligence and risk areas
TLT has a whistleblowing facility that provides a confidential mechanism for individuals to disclose suspicions of impropriety.
It is the responsibility of all those working for us or under our control to detect, report and prevent modern slavery from occurring within our business or supply chain.
If there are any concerns or suspicions that modern slavery may be present in any parts of our business or supply chain, they should be reported immediately to the Firm's Risk Director.
Our modern slavery strategy and due diligence process is developed and reviewed by our Procurement and Risk and Compliance teams to ensure that we take a coordinated approach across the Firm.
Our firm-wide procurement process has been updated and improved to reflect the Firm's commitment to preventing human trafficking and slavery.
We request all our suppliers to complete an Ethics and Compliance Questionnaire.
The Questionnaire asks suppliers to commit to respecting and supporting international human rights and undertake that they will comply with their obligations under the Modern Slavery Act 2015.
In order to identify and assess any actual or potential involvement in modern slavery in our supply chain, we risk rate suppliers, including according to factors that might indicate a high risk of modern slavery such as the location from which services are provided or goods are manufactured and the sectors or activities which present a high risk of modern slavery.
We have identified that the parts of our business and supply chain that carry a potential risk of modern slavery are predominantly those which involve suppliers providing goods and services outside the UK.
The steps we are taking to assess and manage these risks are outlined in this statement. We have undertaken and will continue to update such assessments and steps on an annual basis.
We continue to build on this process to gain further visibility into our supply chain, including by regular review of our data sets.
We expect our suppliers to adopt the same high standards that we adhere to and have fair employment practices.
We reserve the right to terminate agreements with immediate effect if the supplier commits a material breach.
Performance indicators
We will continue to screen all potential new suppliers and require them to confirm their own and their supply chain's compliance with the Modern Slavery Act.
We will continue to ensure that the responses from the Ethics and Compliance Questionnaire of all current and future suppliers are satisfactory and continue to be satisfactory with regards to their efforts made to prevent human trafficking and slavery.
We will continue to risk assess our existing supply chain.
We will meet formally with each of our key suppliers at least annually and, among other things, address their approach to slavery and human trafficking at those review meetings.
Our standard contract terms contain a contractual right to audit our suppliers. We also receive independent feedback on our performance from key clients who audit their relationship with us as their suppliers.
We will continue to investigate whether there are any other steps we should be putting into place to reduce the risk of modern slavery.
John Wood, Managing Partner