Our commitment
We are a responsible and ethical business, committed to making a positive difference in all that we do and to upholding and furthering the values we have placed at the centre of our business: empathy, excellence, straightforward and together. We are committed to the eradication of slavery and human trafficking, both in our own business and in our supply chain.
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015. It sets out the steps that Stevens & Bolton LLP and other relevant group entities (“Stevens & Bolton”, “us”, “we”) have taken during our last financial year (01 April 2025 to 31 March 2026), and those we plan to take going forwards, to prevent slavery and human trafficking in our business and in any part of our supply chain.
Our structure and business
Stevens & Bolton is a full-service commercial law firm which is authorised and regulated by the Solicitors Regulatory Authority (SRA no. 401245). The firm operates as a limited liability partnership registered in England and Wales (registered number OC306955) and provides a broad range of legal and ancillary services to commercial and private clients predominantly based in the UK, as well as internationally. We are located in the UK, operating from a single office in Guildford, Surrey.
We have around 50 partners and 240 employees. Our Managing Partner is responsible for the day-to-day management of the firm, with support from the firm’s Chief Operating Officer and its Board, which is responsible for overseeing the firm’s governance and strategic management.
The firm’s Risk Committee, comprising senior management and reporting directly to the Board, identifies and manages firm-wide risks, including assessing risks or threats within our supply chain, such as modern slavery.
Stevens & Bolton wholly owns and ultimately controls Stevens & Bolton Trustees Limited, a separate legal entity also registered in England and Wales (registered number 04105828) and regulated by the Solicitors Regulation Authority (SRA no. 351311), which assists in providing trust corporation services.
Our supply chains
We recognise that it is crucial for us to have oversight of our supply chains so that we understand the risks of modern slavery along the chain and take action to mitigate those risks.
We have a centralised Supplier Management Group (which includes the Head of Risk & Compliance, the Head of Technology & Data and other Risk & Compliance lawyers), which manages our procurement relationships with third-party suppliers, ensuring appropriate due diligence is undertaken. Where necessary, risks identified by the Supplier Management Group are escalated to the Risk Committee for further evaluation.
Our supply chain consists of approximately 130 active suppliers that provide products and services to support the operation of our business. These include suppliers relating to:
- Business services operations including recruitment agents, payroll, marketing and digital consultants, and marketing materials;
- Property and workplace management, including building and facilities maintenance, core utility services supply, cleaning, planting, waste management, security and catering;
- Professional services, including external training, audit, tax and insurance services;
- Technology, including systems, software and hardware; and
- Legal service suppliers, including online publishers, litigation systems, research systems and client portals.
As a UK-based law firm with suppliers predominantly located in the UK, we consider the risk of modern slavery and human trafficking within our business and supply chain to be low. However, we cannot be complacent. We recognise that modern slavery and human trafficking is present within the UK economy, as well as being a serious global issue.
We maintain a comprehensive database of all our suppliers, which allows our Supplier Management Group oversight of all of our suppliers. Our Head of Risk & Compliance sits on the Supplier Management Group as well as the firm’s Risk Committee, providing an essential governance link between the two committees and then to the Board. We consider that this structure ensures effective identification of any modern slavery risks and rapid involvement of senior management where required.
Our policies and processes
Internal operating policies
We have adopted a number of Board-approved policies and processes that embed our commitment to preventing modern slavery and human trafficking within our business. They set clear expectations that apply to everyone at the firm and outline the procedures for reporting or escalating concerns.
The following policies support us in mitigating the risks of modern slavery:
- Anti-slavery and human trafficking policy – this policy sets out our zero-tolerance approach to all forms of modern slavery and human trafficking and reflects our commitment to acting ethically and with integrity in all our business relationships. It outlines the implementation and enforcement of effective controls, aiming to ensure slavery and human trafficking is not taking place in our business or supply chains. This policy is a mandatory read for all new staff.
- Anti-bribery and corruption policy – this policy sets out our zero-tolerance approach to bribery and corruption. It explains what constitutes bribery and corruption, how it may arise within our operations, and details the processes all staff must follow to prevent its occurrence. This policy is a mandatory read for all new staff.
- Employee screening policy – this policy sets out the required screening checks we undertake to safeguard against risks of human trafficking and forced labour. All staff are subject to pre-employment and ongoing screening, including ID verification and right to work checks through a reputable third-party provider. Our screening programme forms part of our broader commitment to ensuring ethical employment practices and protecting individuals from exploitation.
- Staff handbook – all staff receive our Staff Handbook upon joining the firm which sets out the high standards of professional conduct and behaviour we expect at work. It includes a strict prohibition on harassment, bullying and intimidation in any form.
- Whistleblowing policy – this policy aims to encourage good faith reporting of any knowledge or suspicions of negligence, compliance breaches, wrongful practices within our business or supply chain or illegal act or omission (including modern slavery). The policy sets out how our employees can raise concerns on a confidential basis and who to contact, including anonymous whistleblowing services and employee charities.
We communicate and enforce all our policies and procedures by making them available to staff through the firm’s intranet. Our policies are regularly reviewed and updated, at least every two years.
We also provide training (explained in more detail below) to ensure they are understood and adopted by everyone they apply to.
We continue to promote awareness of internal reporting channels across the firm and are exploring additional ways to enhance accessibility and transparency of reporting mechanisms, including the deployment of specialist reporting tools to support the identification and escalation of modern slavery concerns.
Responsible recruitment process
It is our standard working practice that child labour, use of worker-paid recruitment fees and compulsory overtime is prohibited within our recruitment process. These safeguards contribute to preventing exploitation and uphold fair and ethical labour standards across our operations.
Our employment contracts with staff clearly outline workers’ rights, including the freedom to terminate their employment at any time. We have engaged our internal Employment legal team to review these contracts to ensure they continue to reflect both our legal obligations and ethical commitments under the Modern Slavery Act 2015.
Supplier protocol
We have a robust supplier protocol which promotes responsible purchasing practices. This includes conducting supplier screening checks, a detailed risk assessment and providing a mandatory due diligence questionnaire to all prospective suppliers.
As part of our procurement process, all suppliers are required to confirm compliance with:
- Section 54 of the Modern Slavery Act 2015 (or demonstrate a commitment to preventing modern slavery in their business and supply chain);
- The Bribery Act 2010; and
- The Criminal Finances Act 2017 (including commitment to preventing the facilitation of tax evasion).
In addition, suppliers identified as higher risk, or having significant business impact, must:
- Provide evidence of relevant policies, including modern slavery, anti-bribery and anti-tax evasion;
- Confirm whether they assess their own supply chains for modern slavery risks;
- Disclose any investigations or prosecutions relating to instances of bribery or corruption;
- Detail any standards or codes of conduct imposed on their own suppliers within their supply chain; and
- Confirm that appropriate screening is conducted on their personnel.
Suppliers are assessed on a case-by-case basis by our Supplier Management Group, with those identified as high-risk subject to enhanced screening and Risk Committee review, where appropriate. This approach enables us to identify and prevent slavery and human trafficking threats effectively.
Since our last statement, we continue to strengthen and improve our supplier onboarding and risk assessment processes to ensure proportionate but thorough due diligence is applied across all supplier engagements.
Our supplier onboarding framework is under refinement and will involve transferring our central supplier database to a different platform. The upgraded database will embed enhanced data capture and be designed to incorporate modern slavery as a standing risk consideration for supplier onboarding and ongoing supplier reviews. This will strengthen consistency and oversight of our supply chain risks and enable us to improve the collection of useful data to support key performance indicators in relation to modern slavery.
Assessing and managing risk
We consider the risk of modern slavery and human trafficking within our business and supply chain to be low, given the size, location and nature of our business. In the financial year covered by this statement we have had no incidents of modern slavery identified or reported. However, we acknowledge modern slavery risks can change, and we continue to assess and manage these risks and our processes on an ongoing basis.
We use a variety of different sources to identify and assess our organisation’s overall exposure to modern slavery risk. These risks are primarily identified through desk-based research and sources, internal reviews, engagement with staff and data collected through supplier due diligence questionnaires.
To strengthen our approach to identifying and evaluating modern slavery risks, we have formally established a dedicated Modern Slavery Group, comprising the Head of Risk & Compliance, Responsible Business Manager and a Risk & Compliance lawyer. The Group meets quarterly to oversee our approach to identifying, assessing and mitigating slavery risks across our operations and drive internal awareness of modern slavery and human trafficking risks. The Group works alongside our Supplier Management Group and Risk Committee to ensure a consistent and collaborative approach, with the Head of Risk & Compliance’s involvement in all three groups providing a vital governance link.
Due diligence and mitigation
Although in the past year Stevens & Bolton has not been made aware of any incidents of modern slavery or trafficking, we nevertheless take steps in relation to our people, our clients and our supply chain to ensure that the risk of any such incidents is mitigated, and that any incidents occurring would be picked up and reported, so that they can be dealt with appropriately at senior level.
Our people –
- We apply the highest standards to the recruitment and employment of our people, including screening prospective employees. We employ qualified, and/or otherwise skilled and experienced staff in compliance with all applicable UK employment legislation.
- We are a UK regulated law firm, subject to the SRA’s Standards and Regulations. Our people are under a professional obligation to act in a way that upholds the constitutional principle of the rule of law; in a way that upholds public trust and confidence in the solicitors’ profession; with integrity; and in a way that encourages equality, diversity and inclusion.
- All staff are required to uphold the standards we outline in our Staff Handbook and adhere to our firmwide policies and practices. These are proportionate to meet the modern slavery and human trafficking risks that we face and include our internal anti-slavery and human trafficking policy and anti-bribery and corruption policy. We have grievance and disciplinary procedures in place for non-compliance with our policies.
- We are an accredited Living Wage Foundation employer which means we have committed to pay all our employees a fair living wage.
- In the last financial year, we have progressed the development of a centralised list of preferred recruitment agents. Any agent we engage to source personnel must complete our supplier approval process and agree to our standard contractual terms to be considered a preferred provider. These terms include a requirement to implement and enforce appropriate procedures to identify the risk of modern slavery in the agent’s own business and supply chain and provide appropriate training to its personnel.
Our clients – we have comprehensive client acceptance procedures that enable us to assess the risks involved in accepting instructions from a client. Any instructions that are considered to be higher risk (which may include concerns around slavery and human trafficking) are subject to further risk assessment and may be referred to our Risk Committee.
We also provide advice to clients in relation to managing their own Modern Slavery risks. In particular, in the past year we have:
- Advised clients in relation to drafting Modern Slavery statements.
- Prepared Modern Slavery policies for clients, to supplement their statements.
- Advised on the practical aspects of publication, including hosting and maintaining statements online.
- Delivered client training on the latest government guidance and reporting requirements.
Our supply chain – in line with our priorities for the last financial year, we have worked to strengthen the due diligence measures we undertake within our supply chain, including:
- Risk-based assessments of new suppliers, escalating any concerns, including modern slavery or human trafficking risks, to our Risk Committee;
- Comprehensive screening checks on suppliers and beneficial owners, including company credit, PEP, sanctions, anti-money laundering and adverse media checks;
- A tiered approach to our supplier due diligence protocol to identify higher risk suppliers; and
- A centralised supplier database to support standard governance and oversight of supply chain risks. This includes their location, and the nature of the services or products provided to assess and identify any higher risk activities or jurisdictions.
- Applying these measures to existing suppliers, for example, at key contract milestones.
Developing a centralised approach, in conjunction with our improved supplier screening procedures, ensures consistency across supplier quality, resilience and sustainability, while mitigating any potential threats of modern slavery.
We have commenced planning for a structured risk mapping exercise across our supply chain, prioritising key suppliers and, where appropriate, higher-risk suppliers further down the supply chain. This will progress further following the transfer of our revised central supplier database to a new platform and enable us to take a more structured and risk-based approach to identifying higher-risk suppliers and prioritise due diligence accordingly. This exercise will support our due diligence and enable us to identify and mitigate any increased risks of modern slavery.
Our Supplier Management Group meet regularly (around every two weeks) to review prospective supplier risks and due diligence outcomes.
Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking and how they may arise within our business, we provide training to our staff.
Since our September 2025 statement:
- We marked Anti-Slavery Day on 18 October 2025 in the form of a blog published on the firm’s intranet written by the firm’s Responsible Business Manager.
- Modern slavery has been incorporated into our induction programme (from May 2026). It is a mandatory requirement for all new joiners to read, understand and adhere to our Modern Slavery policy.
- The Managing Partner launched our Whistleblowing policy to the firm in November 2025 and further awareness was raised by our People & Talent team. The policy is available on the firm’s intranet and easily accessible to all staff.
- We continue to require all new joiners to read our Anti-bribery and corruption policy and complete an online training course, which includes a mandatory assessment requiring a mark of 80% to pass. Completion is audited.
- We continue to deliver in-person Risk & Compliance training to all staff upon induction to reinforce awareness of the strict ethical framework within which we operate, as a professional legal services provider, and the importance of any reporting concerns.
We are committed to raising awareness of modern slavery on an ongoing basis. In this financial year we intend to:
- Reinforce our approach to tackling modern slavery and maximise understanding within the business of risks and reporting channels in the lead-up to Anti-Slavery Day on 18 October 2026.
- Deliver targeted modern slavery refresher training to our Risk & Compliance, People & Talent and Property & Workplace teams, and other Business Teams senior management. We intend that refresher training will be carried out every two years.
Monitoring and evaluation
We have continued over the last financial year to focus on implementing robust measures to prevent modern slavery within our operations and supply chains. We have made positive progress on these goals but acknowledge the importance of continuing to improve, monitor and review the effectiveness of our anti-slavery measures.
We have reviewed the Government’s statutory guidance, issued by the Home Office, on Transparency in Supply Chains (TISC) which will inform our approach and priorities for identifying and mitigating modern slavery risks in the next financial year.
Key performance indicators
Since our September 2025 statement, we have agreed key performance indicators to support the measurement and continuous improvement of our approach to modern slavery risk management. These indicators are:
- Number of new joiners who completed modern slavery training
- % of new joiners who completed modern slavery training
- Number of staff competing targeted refresher modern slavery training
- % of required staff completing targeted refresher modern slavery training
- Number of supplier due diligence questionnaires completed
- Number of modern slavery incidents identified or reported
We acknowledge the important role of quantitative data in monitoring our progress and the Modern Slavery Group will continue to monitor and refine these metrics to enhance data quality and support more effective monitoring of trends and risk areas over time.
Progress against our 2025/26 priorities
We have set out our progress in the last financial year against our priorities for the year, and our updated priorities for the 2026/27 financial year. We are confident that these goals will enable us to continue to improve in identifying and mitigating modern slavery and human trafficking risks.
2025/26 priority:
Establish a modern slavery group focussing on modern slavery and human trafficking risks, and;
- include the Head of Risk & Compliance and Responsible Business Manager;
- meet at least quarterly to review how we can apply best practice standards appropriately across the business;
- consider appropriate KPIs and related quantitative data collection to support continued improvement in this area
- consider appropriate refresher training for key personal; and
- work with the Supplier Management Group to agree and begin to undertake an appropriate risk mapping exercise in relation to our key suppliers.
Progress made:
The Modern Slavery Group was formed in January 2026.
- The Group includes the Head of Risk & Compliance and the Responsible Business Manager.
- Meetings are held
- KPIs agreed as set out in the statement above.
- 2026 Modern Slavery training and awareness initiatives are under review (explained in further detail below);
- Embedding modern slavery risk criteria will form part of the broader transformation of our supplier onboarding framework.
2025/26 priority:
Ensure modern slavery & human trafficking risks are included as a standard agenda item in all our Supplier Management Group meetings.
Progress made:
- The Modern Slavery Group are exploring ways to define parameters for assessing modern slavery and recording this in the upgraded central supplier database.
- Modern slavery questions incorporated within our supplier due diligence questionnaires have been reviewed and updated by our Responsible Business Manager. The updated questionnaires will be launched alongside the revised supplier protocol later this year.
- The Supplier Management Group continue to review supplier due diligence questionnaires and meet fortnightly to discuss any identified risks, which includes modern slavery.
2025/26 priority:
Reinforce our people’s understanding of the risks of modern slavery & human trafficking by:
- incorporating modern slavery into all Risk & Compliance inductions for new joiners; and
- further increasing engagement in the lead-up to Anti-Slavery Day on 18 October 2025.
Progress made:
- Modern slavery training now forms a mandatory part of all new joiner training.
- Anti-Slavery Day marked in October 2025 by circulating a blog post on the firm’s intranet, written by the Responsible Business Manager.
2025/26 priority:
Re publicise our Whistleblowing policy firmwide to enhance internal awareness of our transparent reporting channels.
Progress made:
- Policy updated and published in November 2025.
2025/26 priority:
Engage our internal Employment legal team to review our employment contracts to confirm they adequately incorporate the necessary requirements under the Modern Slavery Act 2015.
Progress made:
- Employment team engaged and reviewing our employment contracts.
Priorities for 2026/27
We have set a number of new priorities for the 2026/27 financial year, as well as committing to progress further existing priorities, with the aim of further improving our ability to identify, prevent, mitigate and respond more effectively to modern slavery risks within our business.
In the 2026/27 financial year we aim to:
- Continue to develop the role of our Modern Slavery Group and explore ways to expand its membership.
- Leverage internal expertise from our ESG legal team to provide guidance and advice to the Modern Slavery Group to ensure our strategy remains effective.
- Increase engagement and awareness of modern slavery risks and our internal reporting channels.
- Investigate specialist reporting tools to support the identification and escalation of modern slavery concerns.
- Deliver training to Business Team Heads on the new supplier onboarding process which will include escalation channels for identified risks, including modern slavery.
- Deliver targeted refresher training on anti-slavery risks to key personnel by the end of 2027.
- Launch awareness campaign aligned to Anti-Slavery Day on or around 18 October 2026.
- Continue progressing our supplier onboarding framework, including:
- Finalising updates to our due diligence questionnaires.
- Transfer central supplier database to the new platform and embed modern slavery risk metrics.
- Undertake a risk mapping exercise following the launch of the new protocol.
- Complete review to our employment contracts as part of our commitment to ethical working practices.
This statement has been approved by the Board of Stevens & Bolton LLP on its own behalf and on behalf of Stevens & Bolton Trustees Limited.
Signed
James Waddell
Managing Partner
For and on behalf of the Board of Stevens & Bolton LLP
21 September 2026
(1)Stevens & Bolton LLP is a Limited Liability Partnership incorporated in England (registered no OC306955) and our registered office is Wey House, Farnham Road, Guildford, Surrey, GU1 4YD. Stevens & Bolton Trustees Limited is a company incorporated in England (registered no 04105828) whose registered office is at Wey House, Farnham Road, Guildford, Surrey, GU1 4YD.