1. Introduction
Modern Slavery and Human Trafficking Statement
This Modern Slavery and Human Trafficking Statement is made pursuant to section 54 of the Modern Slavery Act 2015 and relates to actions and processes undertaken during the financial year 1 October 2022 to 30 September 2023 and continues to apply thereafter.
This statement outlines the commitment of Courmacs Legal Ltd to preventing slavery and human trafficking within its business operations, supply chains, and any partnering organisations. We recognise an ethical responsibility to take a proactive and risk-based approach to identifying and mitigating modern slavery risks and are committed to acting with integrity, transparency, and accountability.
All members of the Company are expected to report any concerns relating to potential modern slavery or human trafficking risks to management so that such concerns can be investigated and addressed appropriately.
2. Organisational Structure and Supply Chains
Courmacs Legal Ltd operates as a civil litigation company that sources litigation funding and after-the-event insurance to pursue claimant claim streams.
Our supply chain includes, but is not limited to:
- General office suppliers
- Insurers
- Utility providers
- Recruitment providers
- IT software and consumables
- Telephone and internet service providers
- Consultancy services
- Cleaning services
- Legal services
- Investors
The company solely operates within the United Kingdom.
3. Risk Assessment
Due to the nature of our business activities and geographic footprint, we consider there to be a low inherent risk of modern slavery and human trafficking within our direct operations.
We remain mindful that modern slavery risks can arise indirectly through third-party suppliers and service providers. We therefore take a proportionate and ongoing approach to identifying, assessing, and managing such risks within our supply chain.
4. Governance and Responsibility
The Board of Directors has overall responsibility for ensuring compliance with the Modern Slavery Act 2015 and for overseeing the effectiveness of the Company’s approach to preventing modern slavery.
Operational responsibility for anti-slavery initiatives is allocated as follows:
- Policies and Training: The HR Manager is responsible for maintaining relevant policies and ensuring appropriate staff training and awareness.
5. Training and Awareness
The Company is committed to ensuring that staff understand the risks of modern slavery and human trafficking relevant to their roles.
- All relevant staff are required to complete modern slavery awareness training, with regular refresher training thereafter.
- Modern slavery awareness forms part of induction training for new starters.
- Employees also receive training on identifying, communicating with, and safeguarding potentially vulnerable customers.
6. Policies
The Company maintains a suite of policies that support its commitment to preventing modern slavery and human trafficking, including:
- Whistleblowing Policy – enabling workers, customers, and business partners to report concerns relating to the Company’s activities or supply chains confidentially.
- Employee Handbook – setting out expected standards of behaviour and conduct.
- Anti-Bribery and Corruption Policy – promoting ethical business practices and compliance with the Bribery Act 2010.
- National Minimum Wage Compliance – ensuring all employees receive at least the statutory minimum wage applicable to their age.
- Right to Work Checks – verifying and retaining documentation to confirm the lawful right to work in the UK.
7. Due Diligence and Supply Chain Management
The Company undertakes due diligence to identify and assess modern slavery risks within its supply chains. This includes:
- Reviewing Modern Slavery Statements published by relevant suppliers; and
- Requesting completion of supplier due diligence questionnaires where such statements are not available.
This process supports risk identification, raises awareness, and encourages alignment between the Company and its suppliers on ethical standards and legal compliance.
8. Monitoring, Review, and Effectiveness
The Company monitors the effectiveness of its approach to preventing modern slavery through proportionate measures, including:
- Monitoring completion of modern slavery training by relevant staff;
- Reviewing supplier due diligence responses; and
- Periodically reviewing policies, procedures, and risk assessments to reflect changes in the operating environment.
The Company is committed to continuous improvement and to strengthening its practices where appropriate.
9. Approval
This Modern Slavery and Human Trafficking Statement will be reviewed regularly and updated as necessary.
It has been approved by the Board of Directors and is signed by: Darren Smith
