Modern slavery statement

Organisational structure of our business

Mills & Reeve operates as a limited liability partnership registered in England and Wales (registered number OC326165) and is authorised and regulated by the Solicitors Regulation Authority (SRA number 464604) to provide legal services. Mills & Reeve has 171 partners and 1230 employees and consultants nationwide and operates from offices in Birmingham, Cambridge, Leeds, London, Manchester, Norwich and Oxford.

Our employees

Within our business we have a low level of migrant labour.  With the exception of apprentices (who are paid over the minimum apprentice level) and interns, all staff are paid at or above the Living Wage Foundation rate.  We also ensure that our suppliers are paying the living wage, and we refuse to work with those that do not.  We are an accredited Living Wage employer (link here). This means all staff, directly employed by us, are paid a living wage.  

The standard terms and conditions of employment for all of our staff provide for the freedom of the employee to terminate their employment at any time, and state that any overtime is by agreement between Mills & Reeve and the employee.

Mills & Reeve is an inclusive employer, offering flexibility on work and home life balance. We offer wellbeing support for all our staff through our Diversity, Inclusion and Wellbeing programme, managed by a dedicated team of experienced Diversity, Inclusion & Wellbeing professionals. Our support is structured around four pillars of wellbeing: mental, physical, financial, and digital. This includes resources such as wellbeing supporters who serve as mental health first aiders, wellbeing rooms, an Employee Assistance Programme, regular webinars and talks, and weekly online fitness classes. Additionally, we partner with Nudge for financial wellbeing, which sends helpful email nudges on managing money, including budgeting, pensions, investing, and more.

We are very proud to have been listed for the last 21 years in The Best Companies To Work For list (link here). This year we are also delighted to have been named in the Sunday Times top 100 companies to work for (see here). 

We carry out regular employee satisfaction and pulse surveys. Our last employee satisfaction survey (in May 2023) found that we continue to have exceptionally high levels of employee engagement, with 99% of our employees responding they would recommend Mills & Reeve as a good place to work.  89% of our employees said Mills & Reeve genuinely cared about their wellbeing, and 87% of our employees said they felt valued for the work that they do.  Our next employee survey will take place around August 2025.

In 2020, Mills & Reeve signed up to the Mindful Business Charter and we are fully committed to ensuring that the wellbeing of our staff and partners remains a priority, while still providing an excellent service to our clients.

We are also signatories to the Mental Health at Work Commitment, further enhancing our commitment to the wellbeing of our people.  Our 2021-25 Diversity, Inclusion and Wellbeing strategy further demonstrates our commitment to continue enhancing our wellbeing practice.

Our supply chains

Mills & Reeve is a responsible business which is committed to acting with integrity and maintaining the highest professional and ethical standards in all our business relationships, including our supplier relationships. Mills & Reeve has a zero-tolerance policy towards slavery and human trafficking, and we require our suppliers to take the same approach. 

Mills & Reeve’s Procurement Policy mandates that everyone responsible for buying goods and services for the business is expected to observe the highest standards of honesty and fairness, and work in a manner which ensures full accountability, consistent with our Core Values. We are committed to acting ethically, with integrity and transparency, and have policies and processes in place to safeguard against any form of modern slavery taking place within our supply chain:

• We identify and assess potential risk areas in our supply chains.
• We require that all of Mills & Reeve’s suppliers comply with the Modern Slavery Act 2015 and are transparent, accountable, auditable and free of modern slavery and trafficked labour.
• We operate and maintain a preferred supplier list, conducting extra due diligence on suppliers where we perceive there to be a greater risk of slavery and human trafficking, in alignment with the Chartered Institute of Procurement & Supply (CIPS) guidance.
• Our standard terms and conditions of purchase include appropriate contractual provisions to ensure that our suppliers are contractually committed to seeking to avoid the use of slave labour and trafficked labour.

All members of our procurement team have attained and are required to maintain their CIPS Ethical Procurement certificate and actively seek opportunities to source suppliers who pay the Living Wage Foundation rate.

As part of our ongoing risk mitigation, we will:

• Act promptly where a compliance breach has been identified or flagged.
• Continue to feedback lessons learnt into the compliance risk management process.

Our risk assessment

On the basis of the due diligence and analysis of the Mills & Reeve business and our supply chains carried out to date, we consider that Mills & Reeve is currently at a low risk of modern slavery and human trafficking in both the context of our own business and our supply chains. 

We use EcoVadis, a globally recognised assessment platform, to rate our business’ sustainability. This year we improved from the top 25% of companies to the top 15%. Whilst we have made some progress which is reflected in the increased score, we still have three areas which have been identified as a high priority for us to address based on our assessment results. We are currently working on these before our next assessment, which is scheduled for March 2025. Our scorecard is available to view upon request. 

Our policies

This year we have joined the UN Global Compact, the largest corporate sustainability initiative, with the aim to uphold our basic responsibilities to people and the planet by incorporating into our strategy their Ten Principles which focus on Human Rights, Labour, Environment, and Anti-Corruption. 

In addition to our core values which guide how we work at Mills & Reeve, we also have the following policies published on our Intranet (which is accessible by all employees):

• Procurement Policy: Ensures that modern slavery risks are identified within the procurement process.
• Whistleblowing policy: protecting whistleblowers through our confidential reporting process.
• Harassment policy and guidance for employees prohibiting harassment and intimidation.
• Disciplinary policy: prohibiting any threat of violence.
• Safeguarding policy: protecting from harm and promoting the wellbeing of young people and vulnerable adults.
• Equality, Equity, Diversity and Inclusion policy: supporting our commitment to wellbeing in our practice.
• Health and Safety policy: providing a safe environment to our staff.

Mills & Reeve also works with clients to raise the profile of the issue of modern slavery and human trafficking, and to advise on implementing modern slavery compliance programmes. The team will write or contribute to articles on issues around modern slavery, particularly in the context of supply chains (see Protecting reputation - why understanding your supply chain is so important and Coronavirus series: building a thriving supply chain). 

Our due diligence

The procedures set out in this Statement are intended to reduce the risk of slavery and human trafficking occurring in our business and supply chains, and to enable us to monitor potential risk areas in our business and supply chains. 

We will continue to monitor our due diligence on our suppliers by reviewing our supplier questionnaire against CIPS ethical guidance, to ensure our suppliers have robust policies and procedures regarding the Modern Slavery Act 2015.  Our supplier questionnaire includes questions related to inclusion, diversity and wellbeing.  Additionally, we have reviewed our ESG criteria and included modern slavery related questions in our ESG questionnaire for suppliers. 

We will prioritise suppliers within the selection process that can demonstrate they behave in a manner that is consistent with our core values.

Our training/How we address risks of modern slavery

In addition to Mills & Reeve’s policies set out above, training on modern slavery issues is mandatory for our procurement team, and business support directors who approve purchase orders for goods and services to Mills & Reeve are required to undertake more advanced modern slavery training.  Training is also available to those sections of the business directly involved in drafting supply chain type contracts, where modern slavery needs to be taken into account (for example, corporate, commercial, IP, IT, and construction).

Since 2021, all staff members have access to Modern Slavery training courses through our ‘Learning Hub.’  This includes modern slavery awareness training delivered by the Slave Free Alliance with the objective to raise awareness levels of the issues around modern slavery.  This ensures our employees have a greater understanding of the risks and indicator signs of modern slavery.   

Last year we hosted an event in partnership with Unseen, a UK charity supporting survivors of trafficking and modern slavery, bringing a number of businesses from across the West Midlands to hear about the support Unseen can offer to businesses. We have continued to promote the Unseen App to all our employees so they are able to recognise and understand how they can report victims of modern slavery. This year we are exploring the opportunities to further work with Unseen UK.

Declaration – our supply chain goals for this year

In the next 12 months:

• We will continue to review our Procurement Policy and supplier selection criteria to ensure there is no place in our supply chains for slavery or human trafficking.  
• We will be producing our annual communication and progress to show our commitment to the UN Global Compact.  
• We will partner with key organisations to conduct a supply chain audit.
• We will use the information collected from our suppliers to collate information on the ESG credentials of our most critical suppliers. 

This statement has been approved and signed off by the Board on behalf of Mills & Reeve on 2 December 2024. 

Signature:

Charles Staveley, Senior Partner
On behalf of Mills & Reeve LLP

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