This statement applies to the Williams Lea Group Limited and its subsidiaries (“Williams Lea”) and is made pursuant to Section 54(1) of the UK’s Modern Slavery Act 2015 and Section 13 of the Modern Slavery Act 2018 (Cth).
This statement covers the practices that Williams Lea has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain. This statement on slavery and human trafficking is made on behalf of the applicable companies within Williams Lea.
Introduction
Modern slavery is used to describe serious forms of exploitation to include human trafficking, servitude, forced labor, debt bondage, forced marriage, and the worst forms of child labor. Modern slavery includes situations where coercion, threats, or deception are used to exploit victims and undermine or deprive them of their freedom.
Modern slavery is a scourge on society, and it can occur in every industry and sector. It is often linked to other crimes and activities that adversely impact human rights, such as corruption, fraud, and environmental damage. As a leading provider of business-critical solutions, Williams Lea understands that supply chains require constant monitoring and transparency to reduce the risk of human trafficking, and we maintain a zero-tolerance approach to any kind of abuse in the workforce, in our operations, and within our global supply chain.
We are strongly committed to playing our part in eradicating modern slavery by ensuring we act ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
Table of Contents
- Our Business Profile
a. Our Supply Chain
b. Our Supplier Due Diligence
c. Our Global Reach - Our Company Compliance Policies
a. Recruitment
b. Code of Conduct
d. Supplier Code of Conduct
e. Safety, Health, Environment and Quality
f. Sanctions & Embargoes - Grievances Mechanism
- Risk Assessment
- Training and Continuous Learning
- Key Performance Indicators
- Next Steps and Looking Forward
Our Business Profile
Williams Lea is the global provider of skilled business-critical support services to financial, legal, and professional services firms, connecting people, processes, and technology to streamline key business and administrative functions and helping companies adapt to a more virtual and digital workplace.
Built on a strong heritage, great client relationships, and a talented team, Williams Lea is the trusted global outsourcing provider to clients in highly regulated environments.
Williams Lea serves clients in 20 countries across four continents and has 6,00+ employees worldwide. Williams Lea is backed by Advent International, one of the largest and most experienced global private equity investors.
Our Supply Chain
Williams Lea works with a wide and varied network of suppliers to execute and support solutions that we design for our clients.
Supplier due diligence is a critical part of what we provide for our clients and is essential for the security and performance of our own business.
- Over 1,300 suppliers, 30+ countries and 3 major regions
- Our primary spend is on Professional Services including financial services, administrative and recruitment, legal services, and IT suppliers
Our Supplier Due Diligence
All Williams Lea suppliers must go through our due diligence process at the on-boarding stage and are then subject to regular audits and reviews. These audits are based on perceived risk (e.g., country of supplier, strategic importance of supplier, and handling of confidential data). We take a tiered approach to ensure each supplier’s corporate social responsibilities are aligned with Williams Lea’s and, most importantly, the United Nations Global Compact, the UN Universal Declaration of Human Rights as well as the 1998 International Labor Organization Declaration on Fundamental Principles and Rights at Work in addition to full compliance with legislation, including the Modern Slavery Act.
Our Supplier Code of Conduct sets the minimum standards for doing business with Williams Lea and contains specific prohibitions on child labor and forced labor as well as provisions on fair compensation and working hours, health & safety, and environmental protection. We request that the Supplier Code of Conduct be signed by each supplier as part of the onboarding process, with follow up with our key suppliers to ensure our policies are adhered to. We also review supply chain contracts to ensure they contain the appropriate legislative requirements.
If we find breaches of our Code of Conduct and/or the Modern Slavery Act within our supply chain, we will fully investigate all concerns in detail and, if appropriate, the relationship with the supplier will be terminated.
Our Global Reach
Williams Lea serves clients in 20 countries across four continents and has 6,000+ employees worldwide.
Onshore: Our onshore US and UK delivery centers offer highly trained teams who apply best practices to deliver full-scale support for clients with stringent Information Security protocols and Service Level Agreements.
Offshore: Our expert teams provide follow-the-sun support for pitchbooks, presentations, and document creation using globally connected workflows.
Onsite: Our dedicated staff sit at client offices and are fully integrated with your brand, service quality and culture
Williams Lea – United Kingdom
- 1,800+ employees, 20+ nationalities and multiple languages
- Operational 24/7
- Major onshore delivery center in Darwin House at Leeds Valley Park, Savannah Way, LS10 1AB delivering centralized, virtual support services to leading legal, financial, and professional services firms
- Most suppliers are for business operations including printing hardware and software, IT, and other administrative professional services like sales, legal, finance, or other business support functions
Williams Lea – Australia
- 90+employees providing services for advisory and professional firms, investment banking, and property development firms offering office services, onsite facilities, mail and print, records, and presentation services with some reception and corporate hospitality
- Registered office is located at Suite 11, 431 Burke Road, Glen Iris, Victoria, 3146
Most suppliers are providers of professional services, computers and IT equipment and office administrative support services
Williams Lea – India
- 900+ employees, supporting financial, legal, and professional services firms
- Two locations in Chennai (Ascendas International Tech Park and Tidel Park Canal Bank Road Taramani) and one location in Cochin (Muthoot Technopolis Kerala)
- Operational 24/7
- Pan-India talent sourcing for experienced and trained talent
Williams Lea – United States
- 200+ employees in the thriving Columbus, Ohio metro area; 38,000 sq ft facility at 671 S. High Street with ability to double footprint
- 600+ employees in Wheeling, West Virginia, servicing 78+ clients; 82,000 sq ft facility located at 1030 Main Street
- Operational 24/7 with strong local work ethic
- Major suppliers in financial services, copy hardware, and other professional services
Our Company Policies
Our internal policies ensure that we are conducting business in an ethical and transparent manner:
- Recruitment policy – This includes vetting eligibility to work and safeguards our employees against human trafficking or individuals being forced to work against their will. We also respect the right to collective bargaining and freedom of association.
- Code of Conduct – Our Code of Conduct defines the objectives and rules that reflect our commitment to responsible, ethically-irreproachable, and legally-compliant behavior from all employees and contractors.
- Supplier Code of Conduct – Our Supplier Code of Conduct outlines the expectations we have from our supplies to prohibit child labor and forced labor, and to provide an appropriate framework on working hours and conditions and health and safety.
- Safety, Health, Environment, Quality Policy – We are committed to the health and safety of our people and the communities and societies in which we operate and align our health and safety management system with ISO 45001.
- Sanctions and Embargoes Policy – we strive to conduct fair business with legitimate, high integrity people and third parties including vendors and customers, and a mature sanctions and embargoes monitoring program has been established.
Risk Assessment
Annual Risk Assessment
The risks associated with Modern Slavery are assessed and re-evaluated on an annual basis. The risk assessment process has identified two primary areas of consideration:
Supply Chain/Sourcing
In assessing our risk profile within our direct vendors/supplier base, it has been confirmed that our key vendors are world-class companies providing services such as financial outsourcing, employee benefits (health, financial), and IT software/copy and color hardware. These business partners have established practices to manage modern slavery risks and as a result the residual risk assessment is rated as low. In 2022 all these suppliers were given new Supplier Code attestations to sign.
Human Resources
A majority of Williams Lea employees are college-educated and some hold advanced degrees. Our workforce is primarily in administrative positions requiring specific skills and training whose qualifications and skills are therefore very unlikely to be exploited through forced labor. In addition, there is no manufacturing processes or facilities within the business. The risk of modern slavery
exposure is assessed as very low.
The Williams Lea hiring and recruitment practices are stringent and include enhanced background checks and other due diligence at the time of onboarding. Our employees are also routinely screened against multiple sanctions lists to ensure there are no associated risks
Grievance Mechanism
Whistleblowing Hotline:
Where there are concerns regarding any unethical conduct within our business, including any forms of modern slavery, we strongly encourage our employees to report the concern so we may properly and quickly resolve the situation.
An external independent whistleblowing hotline service operates 24 hours a day, 365 days a year, enabling our employees to report matters anonymously, without fear of reprisal, and includes a translation service.
Training and Continuous Improvement
Williams Lea continues to run annual Modern Slavery-specific training that is included in the mandatory Code of Conduct, Ethics, and Anti-Bribery & Corruption training.
Williams Lea launched a new communications campaign for employees – Be a Compliance H.E.R.O (for Honest, Ethical, Responsible and Outspoken) –to keep our workforce informed on compliance topics. Modern Slavery features as a key topic in this communication program.
In 2022 we translated our Code of Conduct and other policies into eight different languages, making it easier for our employees globally to access compliance material, including Modern Slavery, in their native language.
Key Performance Indicators
We will know and understand the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking are not taking place within our business or supply chain if:
- No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified;
- Annual due diligence, where necessary, on our supplier’s code of conduct is completed; and
- Mandatory annual modern slavery training is completed.
Next Steps and Looking Forward
Modern Slavery is unacceptable and one of the worst kind of offenses to humanity. Williams Lea holds a zero-tolerance approach to Modern Slavery, and we will periodically review the effectiveness of our processes and systems to ensure that we maintain a high standard of controls while looking to improve and collaborate within our organization to raise awareness around Modern Slavery.
Any changes will be reflected in future annual statements.
This Modern Slavery Statement was approved by the Board of Directors of Wertheimer UK Limited on behalf of Williams Lea on September 26, 2022.
Clare Hart
Williams Lea CEO
