Modern Slavery Act Statement

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 with respect to the financial year ending 31 December 2024 and sets out the steps taken in that period to continue to ensure that modern slavery and human trafficking are not occurring in our business or supply chains.

Our values

Cleary Gottlieb Steen & Hamilton is committed to the highest standards of social responsibility and ethical conduct. Please see the Sustainable Purchasing Policy for how this commitment is reflected in all aspects of Cleary’s operations.

The objectives of the Modern Slavery Act 2015 are aligned with our values. We are committed to acting with integrity and to developing effective systems and controls to prevent any form of modern slavery and human trafficking.

Organizational structure and supply chains

Cleary is an international law firm which provides global legal services across the key markets of the Americas, Europe, Asia Pacific, the Middle East, and Africa. Staff in the firm’s 16 offices work across our core practice areas which are made up of capital markets, structured finance, mergers and acquisitions, competition, and dispute resolution. Cleary is led by approximately 220 partners and employs around 1,300 lawyers with support from 1,200 professional staff. For more information on how we are structured and regulated, please see Who We Are.

Our supply chains are relatively simple and relate to the goods and services we require in order to operate as a global professional services organization. For example: catering, security and print/document services, audit and advisory services, and software and IT equipment.

Policies and procedures

We have not identified any examples of modern slavery and human trafficking in the last 12 months.

We consider the overall risk of modern slavery and human trafficking occurring within our own business to be low. We also consider our supply chains to be low risk. However, certain suppliers may pose a higher risk as a result of the industry and jurisdictions in which they operate. As part of our on-going commitment, the firm has continued to implement a number of policies and procedures in this area which include:

• Global policies on personal conduct supplemented by a whistleblowing policy. Our personnel are expressly encouraged to report concerns about slavery, servitude, forced or compulsory labor and human trafficking, and are reassured that they may make a report in good faith without fear of reprisals, even if their concerns turn out to be unwarranted.
• Contracting with suppliers on the basis of our own master service agreement where possible. This establishes a contractual obligation with suppliers to comply with all applicable laws, rules and regulations and binds suppliers to our vendor code of conduct. The vendor code of conduct outlines the firm’s requirement that suppliers ensure all work is voluntary, respecting workers ability to terminate employment freely without penalty, and that suppliers shall not traffic nor tolerate the trafficking of persons under any circumstances or use any form of child, slave, forced, bonded, indentured, or prison labour. In addition, the vendor code of conduct sets out the firm’s expectations with respect to supply chain compliance. Suppliers are required to carry out appropriate due diligence on their own suppliers and supply to the firm, on request, details of the due diligence undertaken on their supply chains. The firm reserves the right to terminate supplier relationships where a supplier is in breach of our master service agreement and the terms of our vendor code of conduct.
• An annual screening of our top 20 suppliers over the last 12 months, using a database which screens for allegations and convictions of criminal conduct, including modern slavery and human trafficking. There were no adverse reports for our top suppliers in 2024. Similar screening procedures are undertaken for existing suppliers whose contracts are due for renewal and for prospective suppliers. Where adverse press commentary or allegations of misconduct are found, our central Procurement team based in New York will conduct a risk assessment which ultimately determines whether or not we continue the business relationship for existing suppliers or engage a prospective supplier. Where necessary, we conduct enhanced due diligence which may involve a request for additional information. The firm continues to monitor over 300 existing suppliers using a third-party platform. This screening procedure assesses the ethical, social and environmental risks associated with a supplier, as well as other performance signals. Where the platform identifies a supplier as higher risk, the firm requires a comprehensive assessment to be completed by the supplier to evaluate their environmental, social and governance, and sustainability management systems. Participation is mandatory and the results of the assessment are integrated into the firm’s supplier review processes.

This statement was approved by the members of Cleary Gottlieb Steen & Hamilton LLP, registered number OC310280, on 27^th June 2025.

Tihir Sarkar, Designated Member, 27^th June 2025