Good governance is about making transparent, accountable, effective, equitable, inclusive, efficient and legal decisions and implementing them. It's good for doing business and also for enabling positive impacts on the planet, people, communities and beyond. Our commitment to good governance and embedding sustainability begins with our Executive Board.
Leadership and the Board
Led by the chair, the Executive Board acts as our main governance body, overseeing the firm's strategic development and business activities. Meeting monthly, it brings together representatives from every corner of our UK business – legal teams, business services and our CEO, as well as two non-executive directors who provide independent oversight and constructive challenge. Minutes are shared with the wider partnership and auditors, to promote a culture of collaboration and transparency,
The powers of the Executive Board are set out in a Partnership Agreement, which clarifies the roles and responsibilities of the CEO, to whom powers for the day-to-day operation of our business are delegated. A number of key decisions are reserved for full partner approval and partner meetings take place on a monthly basis. The Agreement also permits delegations by the Executive Board and a Scheme of Delegations was approved by the Executive Board in January 2023. Committees in place include:
- Remuneration Committee - determines partner remuneration;
- Representative Committee - represents the interests of partners;
- Operational Management Team (OMT) - considers operational issues; and
- Risk and Audit Committee - reviews risk factors and audit programme/findings.
To ensure global consistency, an International Board is in place, co-chaired by CEOs from Gowling WLG (UK) LLP and Gowling WLG (Canada) LLP.
The Board reviews and approves the Environmental, Social and Governance (ESG) strategy, key priority programmes and policies and is accountable for its delivery. An ESG Panel comprised of partners, senior solicitors and business services leads, was introduced in 2023 to support decision making.
Vision and values
Our vision
Our values
For our ESG approach, there are anticipated themes that fit neatly under Governance and others that cut across ESG pillars or require a leadership spotlight:
Anti-bribery, corruption and other financial crime
- Anti-Bribery and Corruption Policy and UK Bribery Act 2022: We have a zero-tolerance policy towards bribery, fraud and corruption. We stand firmly in our commitment to deliver the highest standards of ethical conduct and integrity in every aspect of our business and client engagements, across all of our offices. Our Anti Bribery and Corruption Policy, annually reviewed by our General Counsel yeam, covers partners, employees, contractors, suppliers and agency staff.
- Anti-Money Laundering (AML) and Counter Terrorist Financing Policy and Procedure: Allows us to summarise risks, due diligence and management – particularly in relation to onboarding of clients and ongoing monitoring. It is relevant to partners, employees, consultants, applicable contractors and third party suppliers.
- Proliferation Financing: Is the provision of funds or financial services for use in developing, possessing, transporting or exporting weapons of mass destruction; nuclear, chemical and biological weapons and other related finance. The funds or financial services would be provided to parties who are subject to sanctions. Our existing client and matter on-boarding processes enable us to mitigate such risks.
- Tax Evasion Facilitation Prevention Policy and Criminal Finances Act: Outlines a zero tolerance policy towards the criminal facilitation of tax evasion by our people and third parties.
- Compliance: Processes and policies in place include client and matter risk assessments as part of 'Know your Client' checks; suspicious activity reports filed with the National Crime Agency (reporting money laundering or terrorist financing suspicions); mandatory annual training (AML, anti-bribery, data protection, cyber security, sanctions, proliferation financing and tax evasion); approval and registery of gifts and hospitality, anti-bribery risk assessment; data protection impact assessments (required under data protection law); conflict checks; sanctions checks; and insider lists. Incidents raised are recorded and significant breaches reported to the Solicitors Regulation Authority (SRA).
Responsible finance and tax
As would be expected in a international corporate law firm, financial accounts are managed with professional and legal rigor, overseen by the chief financial officer and externally audited by PwC. The UK Tax strategy sets out the approach employed by Gowling WLG (UK) LLP, its subsidiary companies and controlled overseas entities.
Data protection and cyber security
Our data protection and cyber security practices target the safeguarding of sensitive information and protection of unauthorised access arising from cyber attacks. The Privacy Statement outlines how we protect personal information across all offices and is complemented by a Data Protection Policy that applies to our people and any others working for, but not directly employed, by the business. The policy is owned and overseen by the head of compliance (data protection lead) and Board accountability is owned by General Counsel. Some features of our information security strategy are overseen by a dedicated IT Compliance team and supported by General Counsel:
Human rights
Ethics form the backbone of our business, as we are regulated by the SRA with Principles comprised of the fundamental ethical behaviours that we are all expected to uphold. Public trust, honesty, integrity, inclusion and clients are at the very core of how we deliver services. There is always more to be done and we constantly look to tackle the gaps. Some action guiding the way we work includes:
- UN Global Compact - 10 key principles have been adopted including 'Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights; and 'Principle 2: Make sure that they are not complicit in human rights abuses', derived from the Universal Declaration of Human Rights.
- Themed focus - Drawing on United Nations Global Compact (UNGC) guidance, we have initially defined five areas for review – forced labour; non-discrimination (in respect of employment and occupation); working conditions (wages, working hours); digital security/privacy; gender equality and women's rights – signing up to the Business and Human rights Accelerator to inform the development of action plans.
- Supply chain standards - Requires that suppliers agree to our Supplier Code of Conduct, which addresses modern slavery, anti-corruption, equality and diversity, environmental impact and wellbeing. The Code, Contract Management Policy and associated procedures are continually under review.
We comply with the UK Modern Slavery Act and the Compliance team reviews and refreshes the content annually, as required by law. Processes include ongoing review and negotiation of supplier contracts and supplier due diligence across a range of themes from a legal, risk and priority programme perspective.
- Respect at Work Policy - Guided by SRA Principles, the Policy, defines ethical behaviour expected of everyone in our business. We are committed to "providing a working environment in which all our people feel comfortable and in which everyone is treated with dignity and respect, regardless of role, gender, sexual orientation, transgender status, family status, gender identity, marital/civil partnership status, race, nationality, ethnic origin, religion, belief, age or disability".
- Whistle Blowing Policy - There are mechanisms in place to deal with genuine concerns raised from our people, including contractors and agency colleagues. All contact via this channel is taken extremely seriously and without fear of reprisal.
- People First - Established in 2005 and independent from management, People First is an employee representative body comprising volunteer representatives from all teams and roles across the firm. It has its own constitution and in the event that there are multiple candidates for a representative or chair role, it organises elections. It serves as a consultative body where employees can raise issues anonymously, and which management can use as a sounding board for proposals affecting the workforce. Responses to questions and minutes are shared with all.
Reporting and disclosure
A core strand in our
ESG strategy is greater transparency through public disclosure. This centres around the production of an
annual Sustainability report.
As part of our commitment to the UNGC, a Communication of Progress (CoP) is required and, going forward, this will be informed by our Sustainability report and vice versa. The demands of the CoP continue to strengthen in line with global good practice, and our reporting will evolve to mirror changes and UN, client and societal expectations. Our ESG reporting reports by financial year:
Since 2020, energy use and greenhouse gas emissions data has featured in our annual financial statement to Companies House, a requirement of the Streamlined Energy and Carbon Reporting (SECR) Regulations. This disclosure informs the annual Sustainability report. Since 2018, we have been disclosing pay gap data that goes beyond statutory requirements. Our most recent UK Pay Report is publicly available.
Risk and assurance
- Risk - The Enterprise Risk Management process is overseen by the Risk and Audit Committee. A key outcome is the risk register, categorised into six pillars of risk – strategic, operational (IT), operational (non IT), legal and regulatory, people and reputational, financial - 'owned' by directors with ESG themes integral to all areas.
- Audits - An internal programme of professionally executed independent audits is managed by the Assurance team and reflects a wide range of themes and identified risks. An annual audit carried out by EcoVadis tests progress across much of our ESG agenda and the resulting Scorecard is accessible to clients and others on request. British Standards Institution (BSI), our current external International Organization for Standardization (ISO) standard certification body, carries out audits against five adopted standards. Other audits and reviews related to client requests and regulatory requirements are carried out with all findings and actions arising then monitored and reported to completion.
- Standards - We have adopted five international quality management standards and CyberEssentialsPlus, focused currently in the UK. Further thematic standards are used to guide our approach, for example Living Wage Foundation and Great Place to Work.
- Data assurance - Processes continue to evolve to ensure that publicly disclosed data and information are appropriately reviewed, checked and audited for accuracy, authenticity and transparency.
