Modern Slavery Act Statement
This statement sets out the steps taken, including any steps taken in the last 12 months, to ensure that modern slavery and human trafficking are not occurring in our business or supply chains.
Our values
Cleary Gottlieb[1] is committed to the highest standards of social and environmental responsibility and ethical conduct. Our pro bono work reflects the firm’s commitment to good global citizenship and to policies such as diversity, equal opportunities, anti-discrimination and anti-harassment. Our recent work includes staffing a refugee helpdesk to offer front-line support to those displaced by conflict, advising international NGOs providing urgent humanitarian assistance, and supporting displaced Afghans seeking reunification with their families in the United Kingdom. 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. 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 Gottlieb Steen & Hamilton 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. 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 and dispute resolution. Cleary Gottlieb is led by approximately 170 partners and employs around 1,000 lawyers with support from 1,100 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. As a general matter, we would also consider our supply chains to be mainly low risk. However, we acknowledge that 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:
- 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. This policy is supplemented by a global whistleblowing policy which includes specific reference to slavery, servitude, forced or compulsory labour or human trafficking. Firm personnel are expressly encouraged to report suspected breaches of our anti-slavery and human trafficking policy 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.
- A master service agreement which establishes a contractual obligation with suppliers to comply with all applicable laws, rules and regulations. Suppliers are also bound by our vendor code of conduct which we updated in February 2023. The vendor code of conduct contains provisions which outline the firm’s requirement that suppliers ensure all work is voluntary 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 contains provisions which set 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 the firm’s 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. None of the 20 suppliers we screened for the financial year ending 2022 generated a report which contained allegations or convictions of criminal conduct relating to modern slavery and human trafficking. 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 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 may conduct enhanced due diligence which may involve a request for additional information.
Tihir Sarkar, Partner on behalf of Cleary Gottlieb Steen & Hamilton LLP
6 June 2023