Modern Slavery Statement

Slavery, servitude, forced labour and human trafficking (modern slavery) are issues of increasing global concern, affecting all sectors, regions and economies. Modern slavery is fundamentally unacceptable within our business and supply chains and is an important element in our overall approach to business and human rights. 

James McKenzie (Wills) Ltd is committed to respecting, protecting and championing the human rights of all those who come into contact with our operations, including employees, customers and local communities. We accept our responsibility to support transparency and honesty; to find and resolve problems, and to work with others to protect the rights of workers, particularly those who are most vulnerable to abuses such as modern slavery. 

A) COMPANY

This statement applies to James McKenzie (Wills) Ltd (referred to in this statement as ‘the Company). The information included in the statement refers to the financial year 2024/25.

James McKenzie (Wills) Ltd is a Specialist Will Writing company, focusing primarily on providing Wills and related products to employees of large multinational companies. We have been providing Will writing services since 2004 and have been in the employee benefit market since 2007. We currently offer our services to over 200 corporations from a wide range of business sectors including (but not limited to) finance, pharmaceutical, engineering and media. We take a clear and logical approach, offering two distinct levels of service. Wills are tailored to individual family and financial requirements. Demand for our product is consistently high throughout the year and is therefore not seasonal.

B) COMPANY STRUCTURE

James McKenzie (Wills) Ltd is based in the UK, with a head office in East Grinstead. The company is controlled by a Managing Director and two Business Owners. The Management team consists of the Head of Sales and Marketing, Business Development Manager, Account Manager, HR Manager, OPS Manager, Meetings Manager, Project Manager, Team Leaders and Drafting Manager. There are several sub-teams which report to the Management team. 

The labour supplied to the company in pursuance of its operation is carried out across various regions of the UK however most client meetings take place in the capital city of London. 

C) DEFINITIONS

The company considers that modern slavery encompasses:

• Human trafficking;

• Forced work, through mental or physical threat;

• Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;

• Being dehumanised, treated as a commodity or being bought or sold as property;

• Being physically constrained or to have restriction placed on freedom of movement.

D) COMMITMENT

James McKenzie (Wills) Ltd acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions of the Modern Slavery Act 2015. The company understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The company does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour. 

No labour provided to the company in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. 

The company strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK.

E) SUPPLY CHAINS

In order to fulfil its activities, the company’s main supply chains include those related to a wide range of business sectors including (but not limited to) finance, pharmaceutical, engineering and media. 

We understand that the company’s first-tier suppliers are intermediary traders and therefore have further contractual relationships with lower-tier suppliers. 

F) POTENTIAL EXPOSURE 

In general, the company considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it. 

G) COVID-19 

In 2019 the COVID-19 pandemic had taken hold. For several months, the UK was placed into lockdown to stem the spread of COVID-19. This created several challenges for the company, as it did for others across the nation. The company welcomed the UK Government’s decision, as confirmed in April 2020, to allow for a delay of up to 6 months in the publication of modern slavery statements without the risk of facing penalty.

The company concludes that the COVID-19 pandemic did not adjust the risk of modern slavery to a level above that which existed before the pandemic, which is as set out under ‘POTENTIAL EXPOSURE’ above. 

During the pandemic, the Group’s employees still had access to the grievance procedure to raise any concerns that they may have had. In line with emergency legislation passed by the Government, our employees have been paid Statutory Sick Pay during periods of self-isolation where it has not been possible to agree to a temporary period of homeworking.

The company’s modern slavery risks were subject to the same monitoring procedures during the pandemic as at all other times.

H) STEPS

James McKenzie (Wills) Ltd carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers. 

The company has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, James McKenzie (Wills) Ltd will take the following steps to ensure that modern slavery is not taking place: 

• continuously review contracts and include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery

• embed respect for human rights and zero tolerance of modern slavery across the business

• address any identified risks of modern slavery

• disclosure of any identified instances of modern slavery and results of corrective action plans.

I) KEY PERFORMANCE INDICATORS

James McKenzie (Wills) Ltd has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the company or its supply chains. These indicators cover:

• Use of experienced recruitment agents

• Evidence of informal or indirect recruitment

• Terms of Employment

• Physical observations

The indicators are used to assess the risk of the modern slavery during the audits. Should any indicators be discovered, all our employees are encouraged to immediately alert their line manager or the Managing Director to agree on actions. 

J) POLICIES

James McKenzie (Wills) Ltd has several formal and informal feedback mechanisms across its operations to create a culture where employees can share concerns and ideas. The company has the following policies which further define its stance on modern slavery:

• Anti-Bribery Policy – we require compliance, from everyone connected with our business, with the highest ethical standards and anti-bribery laws applicable. Integrity and transparency are of utmost importance to us and we have a zero-tolerance attitude towards corrupt activities of any kind, whether committed by employees or by third parties acting for or on behalf of the company.

• Personal Harassment Policy and Procedure – we deplore all forms of personal harassment and seek to ensure that the working environment is sympathetic to all our employees.

• Equal Opportunities Policy – we recognise that discrimination is unacceptable and although equality of opportunity has been a long-standing feature of our employment practices and procedures, we have made the decision to adopt a formal equal opportunities policy.

• Recruitment policy – we will endeavour through appropriate training to ensure that employees making selection and recruitment decisions will not discriminate, whether consciously or unconsciously, in making these decisions.

• Whistle-blowing procedures – under certain circumstances, employees are protected from suffering any detriment or termination of employment if they make disclosures about organisations for whom they work. Bullying, harassment or any other detrimental treatment afforded to a colleague who has made a qualifying disclosure is unacceptable. Anyone found to have acted in such a manner will be subject to disciplinary action.

• Grievance procedures

• Ethical code of practice

• Third party Code of conduct 

• Code of conduct for employees

K) TRAINING

We have used the Modern Slavery Act as an opportunity to embed a greater understanding of human rights, and importantly, to extend this awareness to other business areas. James McKenzie (Wills) Ltd provides the following training to staff to effectively implement its stance on modern slavery:

• training of all relevant decision-makers within the company on risks, policies and standards related to modern slavery, human trafficking and forced labour

• evaluation of training and its effectiveness via feedback from participants.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Signed