Modern Slavery Act
This statement is published pursuant to Section 54(1) of the Modern Slavery Act 2015 by Carey Olsen and covers the financial year to 30 June 2018.
Carey Olsen is committed to the highest standards of professionalism, ethical behaviour and integrity in everything we do and to contributing to the wellbeing of the communities in the jurisdictions in which we operate.
Carey Olsen (the "Firm") is a multi-jurisdictional law firm, operating through a number of separately constituted and regulated legal partnerships, which provides legal and other client services in accordance with the relevant laws of the jurisdictions in which they operate. We currently operate from offices in Bermuda, the British Virgin Islands, the Cayman Islands, Guernsey, Hong Kong, Jersey, Singapore, South Africa and the United Kingdom. Further details can be found on our website under Legal Notices.
None of the jurisdictions in which we operate has a poor record on slavery and human trafficking.
Carey Olsen is a professional services provider, which predominantly employs professionally qualified and highly skilled people. We sell our time and advice. We consider the risk of modern slavery occurring within our business as very low. Although as a professional services provider we believe the risk of slavery or human trafficking existing within our business to be very low, we are taking steps to ensure we identify any links to, or risks of, being connected with slavery or human trafficking.
The Firm has a zero tolerance approach to modern slavery and we are committed to acting with integrity in all our business dealings and relationships. We have implemented and will enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
The Firm is committed to ensuring that 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 also expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we are in the process of including specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. Our suppliers will be expected to hold their own suppliers to the same high standards.
We comply with all applicable laws relating to employee terms and conditions (including pay) and are committed to the following core values in connection with our staff at all levels in our organisation:
- We value diversity and respect for the individual;
- We believe in teamwork for the good of the Firm and our clients; and
- We believe in the development of all our staff and in rewarding achievement fairly.
Our due diligence process will take account of the following areas of risk:
- We will monitor all jurisdictions in which we currently operate and any in which we decide to operate in the future for vulnerability to slavery and human trafficking (country risk);
- We will identify any areas of our business which may be vulnerable to slavery and human trafficking (sector or industry risk);
- We will assess whether particular relationships or transactions are susceptible to slavery or human trafficking (business or transaction risk).
As part of our initiatives to identify and mitigate risk, we are also in the process of implementing systems to:
- Identify, assess and monitor potential risk areas in our supply chains;
- mitigate the risk of slavery and human trafficking in our supply chains; and
- protect whistleblowers.
To ensure all those in our supply chain and contractors comply with our policies, we are in the process of implementing a supply chain compliance programme. We will conduct due diligence on our suppliers so that we know exactly who we are doing business with. Those suppliers who may be located in jurisdictions with a higher risk of slavery and human trafficking will be subject to greater scrutiny. In the event that we are dissatisfied with the results of that due diligence, we will require adequate remediation to take place or will terminate the relationship.
We provide all of our staff with relevant training on our policies and procedures to prevent money laundering, to counter the financing of terrorism and to ensure that our services are not exploited by those wishing to further tax evasion or conduct other criminal enterprises.
In addition we will train our relevant staff to ensure that they can:
- recognise the risks of modern slavery and human trafficking;
- identify and report potential violations of the Firm’s modern slavery policy; and
- understand the consequences for not complying with the Firm’s policy.