Modern slavery statement

Whether this is required

Section 54 of the Modern Slavery Act 2015 requires a slavery and human trafficking statement from commercial organisations with an annual turnover of thirty six million pounds or more. Bracton Ltd is far below that threshold and is under no obligation to publish anything.

It publishes this because a firm carrying out supplier due diligence asks for it, and because a company that would sooner say nothing until the law compels it is telling you something about how it treats every other obligation.

What the company is

Bracton Ltd is a private company registered in England and Wales. It develops and will sell case and client management software to law firms in England and Wales. It has one director and no employees. It has no premises of its own, no manufacturing, no physical product, no warehousing, no distribution, no agency labour and no recruitment intermediaries. It engages no subcontractors at the date of this statement and has no operations outside the United Kingdom.

The risk of modern slavery in operations of that description is as close to nil as an operation gets, and saying otherwise would be theatre.

The suppliers

The company's supply chain is short and consists almost entirely of software and professional services. Cloud hosting and storage, software subscriptions, accountancy, legal advice, insurance broking and banking. Those suppliers are established businesses in the United Kingdom, the European Union and the United States, operating in regulated markets, and the larger of them publish modern slavery statements of their own that meet obligations Bracton Ltd does not yet have.

The one category carrying any real exposure is hardware. Computing equipment has a manufacturing supply chain reaching into jurisdictions where forced labour is a genuine risk, and a company of this size buying a laptop has no leverage over it. What the company does instead is buy from established manufacturers that publish their own statements and audit their suppliers, keep equipment in service for as long as it works rather than replacing it on a cycle, and buy less.

What the company does

Bracton Ltd does not tolerate modern slavery or human trafficking in its business or its supply chain, and would end any engagement where it found either.

Before entering a material supply relationship, the company checks whether the supplier publishes a modern slavery statement and reads it. Where a supplier of any size cannot show a credible position, an alternative is used. That is a proportionate check for a company of this size, and it is the whole of the process rather than a summary of a larger one.

Anyone with a concern about modern slavery connected with this company or anything it buys can write to the director at hello@bractonlegal.co.uk, or contact the Modern Slavery Helpline on 08000 121 700 or at modernslavery@unseenuk.org. Nobody will be penalised for raising a concern in good faith.

What happens when the company grows

The parts of this statement that are true because the company is one person stop being true the moment it is not. When Bracton Ltd first engages an employee, a contractor or an associate, right to work and identity checks become part of engaging them, the terms on which they are engaged will carry compliance obligations, and this statement will be rewritten rather than extended.

Where the company's turnover approaches the threshold in section 54, the statement becomes a statutory one and will be prepared, approved and published on that footing.

Approval

This statement is published voluntarily and is approved by the sole director of Bracton Ltd. It is reviewed annually and on any material change to the business or its suppliers.