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 with organisations such as the International Refugee Assistance Project, The Entrepreneurial Refugee Network and Toynbee Hall reflect the firm’s commitment to good global citizenship and to policies such as diversity, equal opportunities, anti-discrimination and anti-harassment. 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 190 partners and employs around 1,200 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: 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 jurisdiction 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 procedure for the appointment of suppliers which requires prospective suppliers to complete the firm’s supplier profile. The supplier profile 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. The information provided is then sent to our central Procurement team based in New York which conducts a risk assessment which ultimately determines whether or not we engage the supplier. Where necessary, we may conduct enhanced due diligence which may involve a request for additional information.
• A supplier code of conduct, which outlines the firm’s expectations 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 amongst other things, the prevention of involuntary labour and human trafficking, 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 our Risk, Facilities and Procurement teams assess on-going compliance with our code of conduct through supplier appraisals and quarterly or annual business reviews. We reserve the right to terminate supplier relationships where a supplier is in breach of our code.
• An annual screening of the top 20 suppliers with which the firm engaged most in 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 generated a report which contained allegations or convictions of criminal conduct relating to modern slavery and human trafficking.

 

Sunil Gadhia, Partner on behalf of Cleary Gottlieb Steen & Hamilton LLP

June 12, 2020