Our firmwide ethics policy contains a number of broad principles which apply to everything we do. These are based on our core values of service, responsibility and integrity. We recognise that our reputation is based on the quality of the services we provide and the way we conduct ourselves. Our clients expect a consistent level of service from all our offices. For that reason, it is important that the standards we set ourselves, and the policies and processes which reflect and support those standards, apply to everyone in the firm.
We are committed to working with our suppliers and building safeguards into our procurement process to ensure that suppliers meet our own ethical and operational standards.
Human rights due diligence
We recognise that the first two principles of the UN Global Compact (that businesses should support and respect the protection of internationally proclaimed human rights and make sure that they are not complicit in human rights abuses) have an impact on our dealings with our clients. Therefore, a question has been included in the risk assessment process for each new client. This reflects the principle, also contained within the UN Global Compact, that business enterprises must “seek to prevent or mitigate adverse human rights impacts that are directly linked to their … services by their business relationships, even if they have not contributed to those impacts".
Our Risk Management and Conflicts teams have developed a thorough process to identify whether there is any evidence of a potential client’s direct involvement in breaches of internationally recognised human rights. We take these responsibilities seriously and have, for example, turned down an instruction on the grounds of potential sanctions breaches where, if the equipment our client was purchasing had been used against citizens of the country involved, the consequences could have been serious.
Risk management and governance
We have a comprehensive set of risk management policies and procedures aimed at ensuring that our firm operates in a responsible, professional and ethical manner, and that it consistently achieves high standards.
We have an Ethics Policy which sends a clear statement to partners, employees, clients and suppliers as to conduct which is appropriate, and that which is not. We also have policies and procedures in place in relation to anti-corruption and anti-money laundering, and indeed many of our other policies and procedures are driven to a large degree by the need to maintain high standards, to treat staff, clients and others fairly, and to act with integrity at all times.
Our policies and procedures are communicated clearly to the firm’s staff, by email from the Managing Partner or the Director of Risk Management (emphasising the endorsement of senior management) and on the firm’s intranet. They are reinforced with the use of training, as appropriate. Staff are encouraged by senior management to familiarise themselves with, and to adhere to, the firm’s risk management policies and procedures, and to report any problems or issues that they may become aware of as soon as possible. For example, staff receive training on the types of situations that must be reported promptly to senior management, from client care related issues, through to breaches of the rules and principles of equality and diversity. The firm has an “open door” culture, but has also set up an anonymous whistleblowing service to ensure that even the most sensitive issues can be disclosed and addressed.
An Ethics Committee, chaired by our Senior Partner, monitors the firm’s compliance with our ethical obligations and commitments and suggests actions which should be taken to ensure that we continue to do so.
Supply chain management
We recognise the indirect impact of our relationships with suppliers and contractors. We consider collaboration and knowledge-sharing to be the most successful driver of success in this area, and have hosted several CR round-table events with our key suppliers to debate the issue of corporate responsibility across sectors.
This year, we reached further into our supply chain to include third party suppliers in the
roundtable discussion, led by Keith Cotton, director of CrispAir Solutions and Julian Taylor, a partner in our employment group.
“I enjoyed the Simmons & Simmons CR Roundtable meeting, which was a very interesting and informative event. It was unusual to be invited as a ‘third party’ supplier, but good to be included in the discussions around the environment and diversity and also to network with the other organisations who attended.”
Paddy Byrne, Group CSR Manager, Premier Paper Group Ltd
The discussion focused on air quality and employee welfare, specifically on the benefits of suppliers acting collaboratively to improve their performance, reduce their impact on the environment and ensure that their people are treated with fairness and respect.
In addition, we annually audit our top suppliers via our corporate responsibility audit that covers environmental best practice and diversity monitoring. This year, we have particularly focussed on our relationship with recruitment agencies and have undertaken a full and comprehensive review of all agencies on our preferred supplier list. New terms of business have been introduced with all agencies being required to have robust equal opportunity practices and to monitor the diversity of their candidates.
Partnering with clients and suppliers
We recognise the value and increased impact of involving both our clients and our suppliers in our corporate responsibility programme. This year we were delighted to partner with pharmaceutical client GSK, on site suppliers Williams Lea and Baxter Storey and recruitment firm Fox Rodney on our Young Talent work experience programme. GSK and Fox Rodney both ran thought provoking skills based sessions to the students. Williams Lea and Baxter Storey offered work experience and shadowing opportunities.
Chartered Alternative Investment Association (CAIA)
Robert Koller, partner and pro bono champion for Germany, heads the German chapter of this non-profit organisation which aims to educate on alternative investments. In March 2012, Robert organised a three day roadshow event on renewable energy in Düsseldorf, Frankfurt and Munich, in cooperation with the Bundesverband Alternative Investments (BAI). Over the last year, Robert has organised a series of events that allowed the alternative investment community in Frankfurt to meet and exchange views. In April 2013, he organised an event in co-operation with the German CFA Society, together with Partners Bernulph von Crailsheim and Jochen Kinderman, on the “New Framework for Alternative Investment Funds – Case Study: Retail-Funds for Renewable Energies”.
We continue to advise and work with Five Talents on micro-finance initiatives in East Africa. These initiatives help the economically active poor to lift themselves out of poverty by starting small businesses. Our London office Litigation and Employment teams have partnered with one of our financial institution clients to advise on employment, bribery and corruption issues. Emily Agnoli, associate in Litigation and Fraser Cocking, associate in Employment advised Five Talents on drafting of volunteer agreements, Bribery Act compliance and issues relating to transferring funds overseas. The firm’s Charitable Foundation also provided a grant to support the Five Talents programme in Uganda. The programme seeks to alleviate poverty among those who are poor but economically active by improving their access to small-scale credit and business management skills.
A selection of photos from the Five Talents programme in Uganda which was supported by the firm’s Charitable Foundation. Left: Sylvia took out her first loan which she used to start selling tomatoes
Lawyers for Lawyers
Associates in our Amsterdam office, Annemarie van der Kruk, Tessa van Roomen and Viviana Luján Gallegos continue to support Lawyers for Lawyers (L4L), an independent and non-political Dutch foundation which seeks to promote the proper functioning of the rule of law by pursuing freedom and independence of the legal profession. L4L supports lawyers worldwide who are threatened or suppressed in the execution of their profession. Annemarie and Tessa, distribute the letter-writing campaigns organised by L4L focus groups and Viviana is a member of the Latin America focus group of the organisation. Viviana monitors the situation of human rights defenders in El Salvador, Costa Rica, Ecuador, Guatemala, Honduras and Belize.
Last year, the Amsterdam office entered two teams, comprising lawyers and support staff, for the De Snelste Advocaat race event at The Hague. The teams won first place in both distances (5K and 10K) and all proceeds raised went to Lawyers for Lawyers.