Modern Slavery Act Statement

This statement sets out the steps taken to ensure that modern slavery and human trafficking are not occurring in our business or supply chains.

Our values

Cleary Gottlieb¹ is committed to the highest standards of social and environmental responsibility and ethical conduct. Our commitment to policies such as diversity, equal opportunities, anti-discrimination and anti-harassment have recently been recognised by LawWorks and the Human Rights Campaign Foundation. For more information on our workplace and pro bono recognition, please see Recent Accolades.

The objectives of the Modern Slavery Act 2015 are aligned with our values. As a leading global law firm, we are committed to acting with integrity and to developing effective systems and controls to safeguard against any form of modern slavery and human trafficking.

Organizational structure and supply chains

Cleary Gottlieb is an international legal practice which provides legal services across the key markets of the Americas, Europe, Asia Pacific, the Middle East and Africa. Our 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, dispute resolution and litigation. Cleary Gottlieb is led by approximately 190 partners and employs around 1,300 lawyers with support from 1,300 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: local counsel, catering, security and print/document services, audit and advisory services and software and IT equipment. 

Policies and procedures

We consider the overall risk of modern slavery and human trafficking occurring within our own business to be low. As a general matter, we would also consider our supply chains to be mainly low risk however, we acknowledge certain suppliers may pose a higher risk as a result of the industry and jurisdiction in which they operate. As part of our on-going commitment, the firm has continued to implement a number of policies and procedures for the purpose of mitigating any risk 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 our 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.
• All new employees receive training on the firm’s procedures in relation to identifying and avoiding modern slavery. We have also developed 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. We aim to roll this training out to our international offices in due course.

Raj S. Panasar, Partner and Compliance Officer for legal practice on behalf of Cleary Gottlieb Steen & Hamilton LLP

30 July 2018