MODERN SLAVERY STATEMENT – 2024/2025

This statement is made on behalf of Burness Paull LLP (“Burness Paull”) pursuant to Section 54(1) of the Modern Slavery Act 2015 (the “Act”).

Our firm

Burness Paull is a limited liability partnership registered in Scotland (SO300380) with 91 partners and over 620 employees, spread across our three offices in Edinburgh, Glasgow and Aberdeen. We are a full-service, independent law firm working with leading organisations across the UK and internationally. We are regulated by the Law Society of Scotland and the Solicitors Regulation Authority in England and Wales. As a law firm, we always work to the highest professional standards and ensure compliance with the laws, regulations and best practice relevant to our business.

Our approach

We are committed to ensuring that modern slavery or any abuse of human rights has no place in our firm or supply chain. The purpose of this statement is to reinforce our commitment to the protection of human rights within our operations during the latest reporting period. For the period 2023-2024, and going forward, our financial year end has changed from 31^st July to 31^st March. This has shortened our timeframe for implementation of planned actions for the period 2023-2024 to eight months as opposed to twelve.  We have, however, remained on course and this statement sets out the steps we took during this shortened financial year. It also outlines the steps we plan to take in the coming months to effectively manage the risk of slavery and human trafficking occurring in our business and supply chain.

We believe in the importance of developing a culture of zero tolerance of forced labour, human trafficking, or any human rights abuse. We do so through our good business practices and policies, including being a Living Wage Employer. We will continue to champion increased vigilance in this area and are committed to further fostering this culture across the firm through training and awareness initiatives.

We have chosen to be a member of and endorse the UN Global Compact and be an advocate of its Sustainability Goals as the focus of our ESG strategy and commitments. This has provided us with a meaningful focus and framework to bring together many of our existing initiatives and it has also given us an opportunity and the ability to consider areas for improvement. ESG considerations and sustainability are the focus of all our decision-making across the business. In particular, we are focused on the following goals which support our zero-tolerance approach to violations of labour law and human rights:

Our supply chain

As a law firm, we have a relatively simple supply chain, which supports our legal practice and internal operations. As our primary operations are in the United Kingdom, we are compliant with the higher standard of ethical business practice and strong labour regulation within the country.  Our suppliers are also mainly based within the UK and the firm’s relationship with its suppliers is overseen by our Director of Business Services and our Operations Board. We also have a team that manages our supply chain on an operational level, including a dedicated Contracts Manager, Sustainability Manager and Information Security Officer who support those in the business that are responsible for procurement.

Our supply chain can broadly be broken into the following key categories:

• Business Services: including catering, cleaning, travel services and document production and business process services.
• Professional Services: including services provided by auditors, advisors (for example in relation to tax and insurance), consultants and other specialists.
• Facilities: including leases for our offices, services provided by security providers and contractors engaged in relation to fit out works etc. and the purchase of office furniture and equipment.
• Human Resources: including services in relation to recruitment, training, and payroll.
• Technology: including services provided in relation to our systems, software, and equipment.

Based on the type of our suppliers and the nature of the goods and services we purchase, we have assessed the overall risk for Burness Paull contracting with organisations that engage in slavery, forced labour or human trafficking, and consider this to be relatively low.

Our policies and due diligence process

As a signatory to the United Nations Global Compact, we are strongly committed to preventing slavery or human trafficking in any aspect of our business or supply chain. We are confident in our internal policies; we apply the highest possible standards in the recruitment and employment of our people. We also conduct due diligence on our prospective employees prior to them joining Burness Paull. When recruiting, we comply with all employment legislation and any applicable regulations.  Burness Paull is an accredited Living Wage employer and we are committed to fair reward through our policies on salary, bonuses, and benefits scheme. In addition, our partners and employees are encouraged to give back to the community and have dedicated over 1,800 hours of their time for various pro-bono activities. Thus, we consider the overall risk of Modern Slavery existing within our own business to be very low.

In relation to our supply chain, we undertake a regular review of our business policies and procedures to ensure that the preventive measures we take are appropriate and proportionate to the level of risk our suppliers may pose for our organisation.

For the current reporting period, our main activities in relation to our supplier chain were in line with our commitments last year and involved:

• Engaging with suppliers at the point of onboarding/contract renewal to ensure that, where appropriate, contractual terms are in place they cover compliance with all applicable modern slavery, anti-human trafficking and labour laws. In addition, we’ve successfully increased the number of suppliers who have signed up to our Supplier Code of Business and the review of suppliers own materially equivalent code that maps their own compliance.
• Continuing our annual training programme for colleagues who deal with procurement, focusing on raising awareness around sustainable procurement practices which are also in line with our compliance responsibilities. The focus remained on the main ESG topics, including our zero-tolerance approach to modern slavery. It also emphasized the importance of escalating any concerns around modern slavery for further investigation.
• Improving our ESG due diligence for our key suppliers which is fully integrated within our annual review process where relevant.  This helps us track our suppliers’ commitments to ESG, including their commitments to preventing modern slavery, labour law or other human rights violations.

Our future priorities

Over the next reporting period, in order to further reduce the risk of modern slavery and human trafficking in our supply chain, we are committed to:

• Implementing a new tool for enterprise risk and supplier management, with a planned roll out within the new financial year. We strive to build and improve upon our processes via automation. The efficiencies of the new programme and enhanced data gathering will ultimately contribute to our ESG compliance programme. The improved system will streamline the vetting of our suppliers and will allow us to gather data for a higher percentage of our supply chain, so the risk of modern slavery and labour law violations within the supply chain will be further reduced.
• Building on our training programme for colleagues who deal with procurement, focusing on raising awareness around sustainable procurement practices.
• Rolling out information campaign for relevant suppliers taking a targeted approach to the ESG compliance of our supply chain.