Investigations Direct is committed to the highest standards of professionalism, ethical behaviour and integrity in everything we do and to contributing to the wellbeing of communities around the world, and has a zero tolerance approach to all human rights abuses. In this we are committed to opposing modern slavery in all its forms, and we do not tolerate it either within our business itself or within our supply chain.
Our commitment is outlined in our Human Rights and Modern Slavery Policy, and we annually publish a statement on the steps we have taken that year to continue to ensure modern slavery and human trafficking are not taking place within our direct operations or within our supply chain.
Investigations Direct – Modern Slavery Statement 2024
This statement is published on behalf of Investigations Direct as the reporting entity pursuant to section 14 of the Modern Slavery Act 2018 (Cth) in respect of the financial year ended 30 April 2024.
References to "Investigations Direct," "we," "us," "our" or the "firm" are to these above-named entities. This statement identifies the steps that we have taken to mitigate the risk of modern slavery and human trafficking occurring within our operations or our supply chains.
Investigations Direct is committed to the highest standards of professionalism, ethical behaviour and integrity in everything we do and to contributing to the wellbeing of communities around the world and has a zero-tolerance approach to all human rights abuses. In this we are committed to opposing modern slavery in all its forms, and we do not tolerate it either within our business itself or within our supply chain.
As a firm, we are committed to adhering to the following core values in all our dealings with our clients, our people, and our communities:
Investigations Direct is part of Investigations Direct, a global law firm operating through a number of separately constituted and regulated legal entities which provide legal and other client services in accordance with the relevant laws of the jurisdictions in which they respectively operate. Investigations Direct is a professional services business which predominantly employs professionally qualified and highly skilled people. Further information about the Investigations Direct global law firm, including information on the countries in which we operate, can be found on our website by clicking here.
Our supply chain consists of goods and services procured to enable our people to deliver these services. Our relationships with sub-contractors, suppliers and their employees, business partners, agents and others working on their behalf (collectively "Third Parties") principally include professional services and consultancy, property, facilities management, human resources, information technology and marketing.
Working in collaboration with Investigations Direct, our anti modern slavery strategy and due diligence process is developed and reviewed by a cross-functional Sustainable Procurement Working Group, including representatives from our Procurement, Property and Workplace, Responsible Business, and Office of the General Counsel teams. The Working Group is sponsored by our Chief Operating Officer and is accountable to the firm’s Executive and Board. A Procurement Assurance Committee is in place to review Procurement and Supplier related risks. The committee consists of members from Information Security, Procurement, Data Privacy, Legal, Responsible Business and Sustainability, Security & Insurance. Outputs of the Committee go to the Directors of Business & Service Delivery and Responsible Business.
There have been no material changes to our organisational structure or our supply chain during this reporting period.
Investigations Direct’s policy framework includes a range of People and Procurement policies that outline our commitment to modern slavery and human trafficking risks in our business and supply chains. Relevant policies include:
Human Rights & Modern Slavery Policy: makes explicit our commitment to the United Nations Guiding Principles on Business and Human Rights, endorsed by the International Bar Association. This Policy confirms our commitment to respect and support international human rights, and in particular to the International Bill of Rights and the International Labour Organisation's Declaration on the Fundamental Principles and Rights at Work. International Inclusion Guidelines: encourages all our people to value diversity, actively promote inclusion, respect each person's individuality, and to ensure that no partner, employee, agency worker, contractor or self-employed consultant, receives less favourable treatment on the basis of colour, race, nationality, ethnic or national origins, sexuality or gender, disability, age or religion or belief. Our International Inclusion Guidelines are further supported by relevant country level policies. Ethics Policy: embodies the key ethical obligations of the firm and our people. It is pervasive in everything we do and in all our dealings, whether directly related to the provision of legal services or otherwise.
Whistleblowing Policy: offers individuals a confidential mechanism for disclosing suspicions or knowledge of possible impropriety to protect the firm, its brand, people, and clients by delivering an early warning when something goes wrong. This includes matters pertaining to modern slavery. Incident Reporting Policy: offers individuals a mechanism for reporting breaches of firm policies and procedures, and errors, acts or omissions which result in breach of the legal or regulatory obligations of individuals or the firm. All our people have a personal obligation to report such incidents promptly and honestly when identified. Anti-bribery and Corruption Policy: sets out the firm's rules and what is expected of all our people. We expect the same standard of conduct from the firm's contractors and third-party service providers in all dealings on our behalf.
Anti-facilitation of tax evasion policy: sets out the firm’s commitment that it will not engage in tax evasion or the facilitation of tax evasion, and articulates the role and responsibility all our people have in preventing tax evasion and its facilitation. Where appropriate, suppliers are required to adopt the same standard of conduct when acting on the firm’s behalf. Sustainable Procurement Policy: outlines the firm’s approach to integrating the management of environmental, social and economic issues into our procurement management systems. The policy aligns with the Universal Declaration of Human Rights; UN Global Compact Ten Principles; UN Guiding Principles on Business and Human Rights and the Fundamental Conventions of the ILO. This policy has been updated to align more closely with ISO 20400 sustainable procurement standards and is published on our external website, click here. Supplier Code of Conduct: sets out our expectations of third parties providing goods and services to Investigations Direct. It is aligned with the Universal Declaration of Human Rights; UN Global Compact Ten Principles; UN Guiding Principles on Business and Human Rights and the Fundamental Conventions of the ILO. This policy is published on our external website, Click here.
All of these policies have been made available to all of our people on our Intranet.
We comply with all applicable employment laws relating to employee terms and conditions.
Our international health and wellbeing strategy is overseen by an International Steering Committee made up of leaders from across the firm. The committee are sponsored by the Executive and supported by an international working group with representation from all regions, ensuring we take cultural differences into consideration when setting our approach. The Managing Partner of Investigations Direct is on the Steering Committee.
Our vision is to create a firmwide culture where work and great health and wellbeing go hand in hand. Our refreshed health and wellbeing strategy has four key pillars: physical, emotional, social and financial health, and focusses on three key areas:
Promotion of greater wellbeing at work for all: we raise awareness of wellbeing issues to help reduce stigma and make it easier for our people to reach out for help. We encourage open discussions about health and wellbeing in the workplace and have resources and policies in place to support. As signatories of the Mindful Business Charter, we encourage sustainable working practices. We run internal campaigns and hold mental health events that shine a spotlight on the experiences of our people. Provision of support and care for our colleagues: to ensure all our people are supported, we work to embed a diverse variety of resources, skills and good health and wellbeing practices throughout our firm. We do this through initiatives such as our SPEAK Ambassador Programme, which aims to create an environment where colleagues feel comfortable talking about mental health issues in the workplace. With MyCare, our international EAP service, we provide a range of free, confidential health and wellbeing services for our people and their families. Through digital tools such as Unmind we empower people to take responsibility for their own wellbeing.
Prevention of health and wellbeing issues: as well as providing reactive support, we are committed to preventing health and wellbeing issues before they happen. This includes using internal data to understand and track the different needs of our colleagues, ensuring that health and wellbeing considerations are embedded in key business processes, and introducing policies and guidelines (such as WorksmartFlex) to help colleagues find the right work/life balance. We work with clients and across professional and regulatory bodies to collectively identify health and wellbeing issues in our industry and explore new ways of working to address them.
The “New Deal”, introduced in 2022, has been further embedded. This offers our people more flexibility in how and where they work, meaningful recognition and feedback, and investment in careers and ambitions. This is being delivered under three principles: we trust you, we value you, and we invest in you.
Investigations Direct expects our suppliers to adopt the same high standards that we adhere to and have fair employment practices. These standards are reflected in the policies we share with our suppliers and ask them to commit to as part of a tender process, in the case of significant suppliers to the business. They include our Human Rights and Modern Slavery Policy and Sustainable Procurement Policy and specifically deal with modern slavery by including, amongst other things, that our suppliers ensure that employment is freely chosen, child labour shall not be used, living wages are paid and working hours are not excessive.
In the last 12 months across Investigations Direct we have:
Refreshed our supplier segmentation tool and carried out risk and impact assessment to assess the criticality of our suppliers and the potential risks they pose to the firm, which includes consideration of environmental and social risks. Suppliers identified as critical will be reassessed annually or where a significant change in service occurs which may impact the risk profile. The output of this assessment informs the level of the Supplier Relationship Management Framework (Total SRM) that need to be adopted to manage and build relationships with our suppliers; Embedded the International Procurement Policy, which clearly defines the procurement processes for purchasing goods and services depending on the risk and value. This includes completion of the due diligence questionnaire where specified spend and risk thresholds are met which contain questions on modern slavery. Responses to this questionnaire are considered in decisions on whether or not to accept a supplier;
Commissioned a Procurement Assurance Committee to monitor any identified 3rd party risks, and regularly reviews supplier policies and processes to ensure they remain fit for purpose; When appropriate, we continue to use standardised supplier contract templates, in which consideration of Modern Slavery risk and mitigations have been embedded and/or ensure that our Customer Policies schedule (including Modern Slavery Policy) is attached to suppliers’ agreements; Embedded the firm’s Anti Bribery and Corruption policy and procedure, rolled out training which is mandatory for all our people, and implemented an on-line system for managing gifts and hospitality. This includes tools to mitigate bribery and corruption risk in our supply chains. Refresher training will be rolled out to all staff in 2024/24; Developed and further embedded the firm’s whistleblowing policy, procedure, and processes, and promoted use of the third party supported Whistleblowing portal. The portal is available to both internal and external stakeholders. Whistle-blowers using this service can choose to remain anonymous. Training will be rolled out to all our people in 2024/24; and Rolled out Contract Management Training Programme for everyone involved in procurement of goods and services internationally and/or locally which focuses on aspects such as data protection, governance, regulatory compliance & Investigations Direct Policies. The objective is to equip the firm to mitigate potential risks throughout the supplier engagement lifecycle from on-boarding through to performance improvement. We continue to gain further visibility across our supply chain, regularly review our data sets and risk register and ensure the continuous improvement of our approach to supply chain and modern slavery risk management.
The Sustainable Procurement Working Group’s workplan for 2024/2025 will concentrate on further refining human rights risk management processes within the firm’s new supplier management.
Over the coming 12 months there will be a continued focus to improve identifying Supplier risks earlier and proactively throughout the entire lifecycle of the Supplier. This will begin with reviewing how new Suppliers are selected and onboarded by the firm to deliver a consistent approach that aligns to our expectations.
Our primary method of assessing and addressing the risk of modern slavery is through a supply chain ESG risk assessment. Investigations Direct has identified a higher risk of modern slavery in connection with suppliers delivering the following services: building repairs, cleaning, catering, consumables, couriers, office fit-out, security and taxis. We also assess and manage the risk of modern slavery pre-contract with each supplier, and on an ongoing basis during contract management and review:
Pre-contract: as part of our Supplier Management Platform roll out, our suppliers will be screened against various country rating areas including Global Slavery Index. Also, depending on the spend and risk threshold, suppliers will be issued with the Engagement Form and Due Diligence Questionnaire which includes questions designed to identity modern slavery risk and establish what measures potential suppliers have in place. This information is used to decide what mitigating measures are required to manage our risk. Contract management and review: Our standard contract terms contain a clause by which we ask suppliers to commit to respecting and supporting international human rights and undertake that they will comply with their obligations under the Modern Slavery Act or any other similar legislation as well as any of our policies that are shared with them. We also reserve the right to terminate agreements with immediate effect when the supplier commits a material breach.
For contracts where the risk of modern slavery is heightened, we will include requirements for our suppliers to have in place:
a policy commitment prohibiting the use of modern slavery that is approved at board or senior-management level and which sets out its expectations on personnel and suppliers/subcontractors; risk screening and diligence procedures to identify and monitor the risk of modern slavery; corrective action plans to investigate, respond to and mitigate any identified risk of modern slavery; training on modern slavery risk identification and management; and a reporting and/or whistleblowing mechanism for personnel and third parties to report any actual or suspected risk of modern slavery.
Where relevant, we also require that some suppliers pass these commitments down to their own suppliers and subcontractors.
In relation to supplier engagement, the frequency of meetings is dictated by a number of factors, including consideration of the risks posed by involvement in modern slavery. Where possible and appropriate, we try to include in our contracts a contractual right to audit our suppliers. We also receive independent feedback on our performance from certain key clients who audit their relationship with us as their suppliers.
Through ongoing supplier management routines, supplier engagement, and at break points such as contract renewal, the effectiveness of the steps taken to mitigate risk are re-assessed and changed or enhanced where necessary.
There have been no material changes to our principal third-party suppliers, who continue to be businesses which supply services related to the running of our premises (such as landlords, building managers, cleaners, caterers, and security) and supply of the IT equipment, stationery and consumables needed to deliver our legal services to clients.
We recognise that the consequences of global warming and migration, the ongoing situation in Ukraine and the Middle east, and other geopolitical factors, have and will continue to impact the risk of modern slavery across a range of sectors, as does the economic uncertainty and instability these have created. We have undertaken and will continue to update such assessments and steps as necessary to address these and other emerging risks.
The Investigations Direct cross-functional Sustainable Procurement Working Group holds quarterly meetings to measure the effectiveness of our strategy and continuously review our priorities and performance.
Our values promote an open and collaborative culture in which people can speak up safely and in confidence. The firm encourages its people to report concerns to managers, supervisors, and to human resources, alongside which it has two more formal reporting mechanisms in place:
Incident reporting: to report errors or omissions which result in failures to comply with the firm’s policies and procedures, or which could result in a breach of legal or regulatory obligations; and Whistleblowing: a confidential mechanism for individuals to disclose suspicions of impropriety or wrongdoing. Disclosures related to modern slavery can be made via any of the above mechanisms in confidence.
Since 2020 all colleagues with procurement responsibilities or who are supplier relationship managers for key suppliers on behalf of Investigations Direct, within Australia and across Investigations Direct, are required to periodically complete our Modern Slavery Act Practical Training. The completion rate for the most recent round of training was 59%. More recently we have developed a shorter awareness training which we plan to roll out in 2024/24 to a wider group of colleagues in our business who work with suppliers or own supplier relationships, to further increase awareness and understanding of modern slavery within the firm.
The topic of sustainable procurement is integrated into the firm’s new starter induction presentation for staff involved in procurement. All of Investigations Direct’s people are required to undertake mandatory training on policies relevant to their roles and responsibilities, and assurances on compliance is obtained via the firm’s annual Compliance & Professional Indemnity Declaration.
At Investigations Direct, we believe great businesses can make a better world. That’s why, every day, we help our clients to succeed, and be responsible, sustainable businesses. Our view is that, together, we can make business better. The firm has adopted Sustainability & ESG as a strategic priority for the firm, and Impactvise has rated us the number one law firm in the world for ESG performance out of over 1000 law firms globally.
We have a responsible ethos and care about our people, our communities, and the environment, and uphold high governance and ethical standards. As a firm, we actively engage with our people, our clients, and our communities to understand evolving expectations, and ensure we meet and exceed those expectations.
Our Responsible Business strategy encompasses our approach to our people, our communities and partners, and the environment. We have this year refreshed the firm’s Sustainability & ESG SteerCo by appointing regional representatives onto the Committee to ensure that our strategy better reflects local policy, market and stakeholder concerns and approaches from every geography.