Modern Slavery Act

We have undergone a thorough review of our Modern Slavery Act Statement and have refreshed our approach which is effective as of October 2021.

The Modern Slavery Act 2015

The Modern Slavery Act 2015 (“the Act”) signalled a new drive in the fight against slavery. It includes a duty on businesses to play their part in stopping modern slavery in global supply chains. Withers & Rogers (“W&R”) is committed to being a responsible business and complying with the requirements of the Act.

Withers & Rogers refers to W&R Group LLP, W&R LLP, W&R Renewals LLP, and WR Europe SNC.

Section 54 of the Act (Transparency in Supply Chains) requires W&R to publish a statement on its website of the steps taken during the financial year to ensure that slavery and human trafficking is not taking place in any of our supply chains or in any part of our own business.

Suppliers are those businesses that supply either goods or services (or both) to W&R directly.

Firm Structure and Supply Chain

W&R is an IP firm which provides a comprehensive service that extends to both securing IP rights – such as patent, trade mark and design registrations for the UK, Europe and further afield – and advising on their exploitation and enforcement. Alongside, we provide proactive support functions that help our clients keep track of their IP, stay on top of its maintenance, and stay in control of cost.

We are driven by our core values, we are proud of our culture and see it as our purpose to make a difference in our profession through building trusting relationships.

As at our financial year end, 31 March 2022, we had 31 Partners and employed 181 people. We use contractors at times to support our fee earners and business operations.

Our supply chain involves the purchase of goods and services which support the operation of our offices and services to our clients.  Our key suppliers are those that we engage with on a frequent and contractual basis.

W&R operates the following policies and procedures that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.

Supplier Code of Conduct

One of W&R’s core principles is to operate its business both lawfully and ethically, which includes working with suppliers that are aligned to the same values.

W&R expects its suppliers to operate in accordance with applicable laws, respecting individuals’ human rights, and mindful of environmental and safety impacts of products and services.

Key requirements of W&R’s supplier code of conduct are:

• To have policies, systems and or procedures in place to ensure the prevention of unethical business practices, including, but not limited to, human rights abuses, money laundering, corruption, fraud, bribery and other improper payments
• Not to use slave labour, child labour or forced labour, not to engage in or support human trafficking
• To ensure that working hours, wages, overtime pay and working conditions are in compliance with all applicable laws and
• To provide a clean, safe and healthy working environment to protect the occupational safety of all employees.

Culture and Ethics

W&R strives to maintain the highest standards of professional conduct and ethical behaviour. All partners and registered persons are required to abide by the IPREG code of conduct.

We will be guided by our Values:

Encouraging a culture of Inclusivity is important to us at Withers & Rogers. We care about what we do. We understand the difference in working with real people who bring passion and personality to the job to make it much more than filing a patent, TM, design or grant.

Our Values are Being Collaborative, Being Genuine and Being Passionate. Our Values govern our behaviour and:

• Ensure that as a business we act with integrity, and we do the right thing
• Help us all to be the best version of ourselves and encourage an environment that is inclusive and open.

Our Code of Conduct

Our code of conduct is a framework to help us do the right thing. It is an expression of our shared values and the way we do business, which helps us to work openly, honestly and ethically. Our code of conduct is grounded in the IPREG code of conduct which clearly states that we must reject unethical or illegal business practices.

Recruitment

Our policies include ensuring that all candidates produce original documentation indicating that they have the right to work in the UK prior to commencing employment.

Speaking Up

W&R encourages all its employees, customers and other business partners to report any concerns related to the direct activities, or the supply chains, of W&R.

Training for our people

We use Metacompliance to provide annual training on the Modern Slavery Act among other regulatory matters.

Supplier Risk Assessment & Due Diligence

• We recognise our responsibility to identify and address potential or actual human rights impacts linked to the goods and services we purchase
• When we appoint key suppliers we make endeavours to ensure that if they do not have their own modern slavery act statement that they can comply with our statement, namely, ‘to ensure that working hours, wages, overtime pay and working conditions are in compliance with all applicable laws and to provide a clean, safe and healthy working environment to protect the occupational safety of all employees’.
• We do this by communicating our statement on our website along with setting our expectations that our suppliers can agree with our approach. Where we have key supplier relationships we highlight our expectations on our website and communicate our statement. This is predominantly done via written communication (via email) or where more appropriate verbally.

We will continue to review our approach on an annual basis and will enhance our approach if improvements are identified.

This statement constitutes the modern slavery and human trafficking statement of W&R and its subsidiary undertakings, for the financial year ended 31 March 2022. It has been approved by the members and signed on their behalf by:

Fiona McBride

Chair