This statement is published in accordance with Section 54(1) of the Modern Slavery Act 2015 (the Act).
Cooley LLP is an international law firm of over 1,000 lawyers and 2000 employees based across 14 offices located in the US, Europe and China. The Firm is focused on technology, life sciences, venture capital and fund formation, although has expertise in wider areas and a strong disputes practices. Cooley (UK) LLP (Cooley UK) is a Limited Liability Partnership registered in England and Wales. We have a zero-tolerance to modern slavery and are committed to ensure that it does not take place anywhere in our business and no one with whom we do business benefits from or in any way contributes to modern slavery.
As a professional services organisation, we consider the risk of modern slavery within our business to be very low. As a result, we do not maintain separate policies in relation to those matters, nor provide specific training on them to the majority of our staff (although such training will be provided to our HR, Procurement and senior management teams). We have a Concerns at Work Policy which is published on our intranet which enables any member of staff to report any known or suspected breach of our ethical standards including slavery, human trafficking, forced or child labour, without fear of retaliation and also to allow the firm to take any necessary corrective action immediately.
Our Supply Chain
Our "supply chain" in relation to the provision of professional services is straightforward and consists in the main of other regulated professional services – banks, intermediaries, accountancy practitioners, other law firms, barristers, expert witnesses, etc. As such, it is very low risk so far as issues with trafficking and modern slavery are concerned, and so we do not at this stage take or propose to take any specific action in relation to these professional services relationships. If our experience or perception of the extent of that risk changes then this position will be revisited.
We consider that the supply of internal (non-professional) services and of goods may (being for the most part not professionally regulated and/or sourced from countries with less well developed legal protections against exploitation) carry a marginally greater risk of slavery or human trafficking than the supply of professional services. Such services include catering, office cleaning, security and maintenance services, photocopying, transport, hotel/travel booking. At no point before or during the year to January 2019 have we had any reason to suspect the existence of exploitative practices (slavery, child labour or trafficking) in our supply chain.
Non-Professional Supplier Requirements
The conditions to being an approved supplier will apply both on the renewal of existing contracts and on entering new supply relationships. Each supplier has undergone due diligence to assess the risk of it being involved in slavery or human trafficking. Information on the services provided and the contract value have been collated and the level of risk noted. Each supplier has signed up to a Code of Conduct which includes the requirement that the supplier shall:
- take reasonable measures to protect the health and safety of its workforce and workers in its own supply chain;
- not use or permit to be used any slavery or child labour in the fulfilment of any supply of goods or services to us;
- comply with local law requirements as to maximum working hours and minimum pay and rest breaks, etc., and with the other workforce rights applicable under the law and best practice of the relevant country;
- both contractually and actually allow its workforce freedom to leave their employment without the unlawful withholding of money or identity papers to deter or prevent this;
- take reasonable steps to prevent the unlawful treatment of its workforce by internal management or third parties;
- not engage in bribery or similar unethical practices.
Responsibility for Cooley UK’s compliance with the Act lies with the London Managing Partner and the COLP. They will keep under review the steps taken to comply with the Act and will make any necessary changes to the policies and procedures of Cooley UK as they deem necessary.