Modern Slavery Act Statement
As of June 30, 2017
The firm1 is an international legal practice providing legal services across a number of sectors. Staff in the firm’s 16 offices work across practices, industries, jurisdictions and continents to provide clients with simple, actionable approaches to their most complex legal and business challenges, whether domestic or international. We support every client relationship with intellectual agility, commercial acumen and a human touch. For more information on how we are structured and regulated please visit www.clearygottlieb.com.
The firm is committed to the highest standards of social and environmental responsibility and ethical conduct. We consider any form of slavery and human trafficking to be abhorrent and are committed to acting with integrity and appropriate transparency in our business dealings. We are also committed to developing effective systems and controls to safeguard against any form of slavery or human trafficking occurring within our organisation or in our supply chains.
As part of this on-going commitment, we have begun to introduce in certain parts of the firm systems and controls which include:
- An anti-slavery and human trafficking policy, which applies to all personnel of the firm, including attorneys and professional staff who are independent contractors and temporary staff. Among other things, this policy includes procedures for reporting any suspected breach of the policy.
- A supplier code of conduct, which outlines the firm’s expectations for supplier conduct regarding labour and human rights in addition to health and safety, environmental protection, ethics and management practices. The firm requires relevant suppliers to agree to, and operate in accordance with, the principles detailed in the most recent version of the code, which include inter alia the prevention of involuntary labour and human trafficking, the compliance with all laws and regulations in the jurisdictions in which they operate, and the advancement of social responsibility. We ask suppliers to acknowledge that they will adhere to our code and we assess compliance with the code through supplier appraisals and periodic reviews. We reserve the right to terminate supplier relationships where a supplier is in breach of our code.
- A supplier profile, which must be completed by prospective suppliers, includes questions on compliance with labour laws and work practices and solicits confirmation from the supplier that their employees receive at least the legally mandated minimum wages and benefits in the jurisdictions in which they operate. We use the information provided to conduct a risk assessment to determine whether enhanced due diligence procedures are required and ultimately to determine whether or not to engage the supplier.
- A procedure for the appointment of suppliers, which specifies that only suppliers approved in accordance with a specified procedure may be engaged, requires relevant prospective suppliers to complete the supplier profile, confirm their acceptance of the supplier code of conduct and provide any other information determined to be necessary following a risk assessment. The procedure envisages that a formal audit of a supplier may be carried out before entering a business relationship, and it mandates compliance and procurement team members to review periodically service arrangements for on-going compliance with the code.
- A whistleblowing policy, which expressly encourages employees to disclose information relating to suspected incidents of slavery, servitude, forced or compulsory labour or human trafficking at work.
- We have assessed the firm’s own recruitment and hiring policies and we believe there is no discernible risk of slavery, servitude, forced or compulsory labour or human trafficking within our own organisation. We have also assessed these risks in our supply chains. Although, as a general matter, we consider our supply chains to be mainly low risk, we have identified certain suppliers to be higher risk. These higher risk suppliers will be our primary focus over the coming twelve months. We have taken the view that lawyers, auditors and notaries public who are regulated in their local jurisdiction and are engaged by the firm as part of, or as necessary for the continuity of, the firm’s business will be committed to high ethical standards and we have accordingly assessed such suppliers as low risk for these purposes.
- All new employees receive training on the firm’s procedures in relation to identifying and avoiding modern slavery. We are also developing an anti-slavery training programme for our managers, HR senior management team, procurement teams and other relevant staff so that they are aware of the issues surrounding modern slavery and what to do if they or their reporting staff suspect that it is taking place within our organisation or supply chains. This training will initially be provided to staff working in the United Kingdom, but will also be rolled out to our international offices in due course.
We will continue to review, build on, adapt and improve these systems and controls.
This statement is made with regard to the firm’s obligations arising under section 54(1) of the UK’s Modern Slavery Act 2015.
 Throughout this website, “Cleary Gottlieb” and the “firm” refer to Cleary Gottlieb Steen & Hamilton LLP and its affiliated entities in certain jurisdictions, and the term “offices” includes offices of those affiliated entities.