Modern Slavery Act Statement

This statement is made on behalf of Norton Rose Fulbright LLP and Norton Rose Fulbright Services (together, the Firm) in compliance with Section 54 of the Modern Slavery Act 2015. It constitutes the Firm’s slavery and human trafficking statement for the financial year ended 31 December 2023.

As a legal service provider, the Firm recognises its responsibility to uphold the rule of law and respect human rights. We operate in alignment with our Business Principles of Quality, Unity and Integrity, which guide our staff and our activities. Our Business Principles describe our culture, the way we work and what we stand for. We value our people and maintain an environment where individuals feel safe and respected.

The Firm is committed to identifying and mitigating the risks of modern slavery within our own operations, and working with suppliers who respect human rights and share our commitment to maintaining high ethical standards.

This statement demonstrates how we apply our Business Principles in practice and underscores our ongoing commitment to addressing and preventing forced, compulsory, trafficked, or child labour within our organisation and supply chain.

Our Structure, Business and Supply Chains

Norton Rose Fulbright is a large, co-ordinated legal practice with offices worldwide. The Firm operates under a Swiss verein structure comprising five member firms and their subsidiaries and affiliated entities.

The Firm has offices in Amsterdam, Athens, Bangkok, Beijing, Brussels, Casablanca, Dubai, Düsseldorf, Frankfurt, Hamburg, Hong Kong, London, Luxembourg, Milan, Munich, Newcastle, Paris, Piraeus, Riyadh, Shanghai, Singapore, Tokyo and Warsaw. The 4 other member firms are domiciled in the USA, Canada, South Africa and Australia.

Norton Rose Fulbright provides legal services to business enterprises, governments, and public sector organisations, focussing on six key industry sectors:

• Consumer Markets;
• Financial Institutions;
• Energy, Infrastructure and Resources;
• Transport;
• Technology; and
• Life Sciences and Healthcare.

The Firm’s suppliers fall into several broad categories:

1. Real Estate and related services: the Firm leases offices across Europe, the Middle East and Asia, requiring maintenance, security, catering, cleaning and other services.
2. Professional Services: this includes insurers, banks, accountants, auditors, translators, administrative services, marketing, legal counsel and recruitment agencies.
3. Travel: airlines, rail and taxi companies, travel agencies, hotels and other accommodation providers.
4. Technology: software and hardware retailers, consultants, maintenance companies and technology related service providers.

The Firm integrates its Additional Terms of Purchase for Goods and Services into its contracts with suppliers. A key provision within these terms requires suppliers to comply with the Firm’s Supplier Charter, which outlines our commitment to ethical practices, human rights and environmental sustainability.

Our Supplier Charter outlines the Firm’s ethical expectations for suppliers and is fundamental to all new supplier relationships. It requires that suppliers conduct their business activities in accordance with human rights principles as defined by the United Nations Universal Declaration of Human Rights and the core conventions of the International Labour Organisation. Specifically, the Charter mandates that suppliers “must not hold another person in slavery or servitude, employ, engage or otherwise use forced or compulsory labour, trafficked labour or child labour; nor engage in or condone the use of corporal punishments or mentally, physically or sexually abusive or inhumane treatment of workers”. The Supplier Charter also requires suppliers to abide by all applicable laws (for example, anti-bribery & corruption and health & safety).

These documents are available on the Firm’s website, for transparency and accountability.

The Firm has implemented robust measures to identify, assess and monitor multiple risks associated with vendors, including but not limited to modern slavery related risks (for example, financial crime, financial distress, data protection). Staff and management involved in the procurement of goods and services (including members of our accounts payable team who manage payments to vendors) undergo training to properly identify, assess and monitor potential human rights issues. Our governance channels require identified high risk scenarios to be escalated to internal subject matter experts for assessment and where appropriate, approval.

Policies

At Norton Rose Fulbright, we prioritise ethical conduct in all aspects of our operations. We have established a range of robust policies which guide the actions of those operating within the Firm, ensuring we uphold the highest standards of integrity. Among these policies is our Human Rights Policy, which underscores our commitment to respecting internationally recognised human rights standards. We work to ensure compliance with these policies by having effective procedures in place, relevant training, and oversight.

Human Rights

Our Human Rights Policy sets out our expectations for the conduct of our staff and our business partners, providing a framework for continuously assessing our direct and indirect impact on human rights. Covering both the Firm’s interactions with suppliers and client onboarding, the Human Rights Policy mandates measures to elevate awareness and ensure compliance. Pursuant to the Policy, we take steps to support our client’s respect for and understanding of human rights through training, monitoring and mitigation of risks, adherence to applicable laws and contractual obligations, and by adopting best practices.

Our commitment to this Policy is extended and supported by the provision of business and human rights (BHR) training to the Firm’s partners and staff. This training comprises a compulsory e-Learning module which introduces our BHR agenda and an explanation of the main principles of the Policy and its relevance to our staff, according to their specific functions. It is designed to empower staff to take responsibility within their role to uphold the principles of the Firm, by providing the relevant knowledge and tools to navigate these issues.

Oversight and guidance of adherence to our Policy is provided by specialists within the Firm’s Risk and Compliance team, who bring expertise in navigating human rights and ethical issues. Through subject matter expertise and knowledge of regulatory frameworks and industry best practices, this ensures our policies are implemented and aligned with our business operations. Regular audits and training initiatives are used to foster a culture of compliance and ensure our Business Principles are adhered to within the organisation.

These issues are further overseen by our Audit Committee, Social Impact and Sustainability Team, and our Responsible Business Committee. These bodies are comprised of senior individuals within the Firm who drive the Firm’s strategy on human rights related issues (amongst other things) and monitor compliance.

Modern slavery risks tend to be high in environments where racism and other forms of discrimination are tolerated. The Firm has Global Practice Standards which are designed to ensure that our behaviour conforms, at all times, with our Business Principles. One of our Global Practice Standards is that we do not tolerate discrimination in any form.

Employment / Reporting

Our Ethical Reporting “Report It” Policy encourages all staff to promptly report any known or suspected violations of our ethical standards. This includes issues such as slavery, human trafficking, forced or child labour, and broader human rights concerns. The Policy ensures anyone who comes forward can do so in confidence, providing examples and clear procedures for reporting. Reporting of slavery, human trafficking, forced or child labour will require immediate attention and escalation to senior management within the Firm.

This Policy applies to all individuals working for Norton Rose Fulbright (whether in a permanent capacity or on a short-term basis) in any jurisdiction, including partners, avocats collaborateurs, employees, consultants, agency workers and contractors.

Our Employee Handbook, which serves as a central repository and reference point for employee-related policies, has been updated to take account of modern slavery issues. This document helps to ensure that staff understand their rights, responsibilities and the ethical standards required of them by the Firm.

Due Diligence / Risk Assessment and Mitigation Processes

Employment

The Firm upholds the highest standards in the recruitment and employment of our people. In addition to ensuring compliance with the policies outlined in the Employee Handbook, we:

• Ensure compliance with all legal obligations during the recruitment and onboarding process, with a particular focus on verifying individuals’ right to work in their respective countries of engagement.
• Conduct thorough due diligence on prospective employees, including a rigorous selection process and various background checks (including employment references) both prior to hiring and annually for employees responsible for compliance with key internal risk management policies.
• Recruit, promote and develop our workforce based on merit and capability.
• Maintain a robust Diversity and Inclusion policy to foster a diverse workforce and an inclusive culture, including affirmative action initiatives aimed at supporting individuals from Black, Asian, and Minority Ethnic backgrounds who meet our merit and capability criteria.
• Uphold the Firm’s Respect in the Workplace Policy, ensuring a supportive and respectful work environment for all.

All staff and partners are expected to adhere to our Global Practice Standards, Business Principles, and relevant regulatory requirements and professional codes of conduct. These expectations are outlined in our employment contracts, ensuring clear communication of our ethical and legal obligations from the outset of employment.

Our ongoing training programmes provide guidance on these standards and ensure staff have the relevant knowledge to properly carry out their roles. These commitments are reinforced by the Firm’s policies, as detailed in our Employee Handbook, which undergo regular updates to reflect legal and industry standards and best practice.

The Firm conforms to the London Living Wage for its London employees and complies with all regulatory requirements in each office in which we operate.

Our Clients

As a law firm, we operate within a highly regulated environment and must comply with applicable legislation and professional codes of conduct that require us to conduct due diligence on our clients and identify our scope of engagement. In accordance with our ethical commitments, our overriding principle is that we will not act for clients in circumstances where it is illegal or inappropriate to do so. Should any suspicions of illegality or impropriety emerge during the course of a matter, we have established robust internal and external reporting mechanisms. These include subject matter experts and senior management within the Firm.

The Firm’s Human Rights Policy states that when opening new matters for clients, the Firm will “implement processes to assess potential human rights impacts and take these into consideration”.

The Firm’s client and matter induction process is sophisticated and comprehensive. Our dedicated Risk and Compliance team members have been trained to assess the human rights records of the client, counterparties and any relevant jurisdiction(s), during the client due diligence and matter opening processes. Clients are also monitored for such risks throughout the course of the client relationship. Where escalated human rights related risks are identified, the Risk and Compliance team will research and assess those risks, consider and recommend mitigation strategies (for the Firm and client) and escalate to senior management where appropriate.

The Firm’s Partner Quarterly Return Questionnaire collates information on partners’ reflections on human rights issues in relation to all of their matters. We alert our clients to human rights issues which may arise in their transactions or commercial practices and work with clients to resolve such issues. This may include the provision of advice on how to improve their internal policies and procedures to ensure compliance with human rights related legislation and international standards.

Pro Bono

We know that as a law firm we have distinct skillsets and it is important that we use those skills to address global and local legal needs. We empower our staff to do so through our pro bono practice across a diverse range of settings and causes, where they can make a positive impact.

In 2023, the Firm renewed its commitment to the England & Wales Law Society’s Pro Bono Charter. In addition, we signed the Global Refugee Forum Legal Community Pledge, committing to providing pro bono support to displaced communities for the next four years.

The Firm continues to make strides in its commitment to pro bono work and strives to meet the aspirational target of 25 hours of pro bono work per lawyer per annum, which we have adopted through our membership of the UK Collaborative Plan for Pro Bono.

Effectiveness Tracking

The Firm has achieved the following KPIs since our previous report: 

• completion of an internal audit and review of the Firm’s vendor engagement, vetting and monitoring processes (which is part of a broader vendor management project);
• review of modern slavery risks in the Firm’s Business Risk Assessment;
• effective collaboration within our fellow member firms on human rights and modern slavery initiatives, particularly with colleagues within Norton Rose Fulbright Australia regarding vendor management best practices and resources; and
• completion of phase 1 of a BHR due diligence review of our Milan, Riyadh and Tokyo offices. This involved an analysis of the respective jurisdictional human rights risks and assessment of the suppliers to each office. Phase 2 of this project will involve consideration of client and matter risks, employment risks and identifying actions tailored to each office to mitigate modern slavery risks.

We shall report on our performance against the following KPIs in our 2025 Modern Slavery Act Statement:

• phase 2 of our BHR due diligence review of our Milan, Riyadh and Tokyo offices;
• implementation of legal technology (“Intapp Terms”) which will enable the Firm to better track and report on client engagement terms which cover human rights and modern slavery related measures;
• finalisation of the Firm’s vendor management project; and
• a Firm wide modern slavery awareness event in October 2024 to mark Anti-Slavery Day and the Firm’s commitment to addressing modern slavery related risks.

Targeted Focus

The Firm has a dedicated Responsible Business Committee which continues to address issues of business ethics and human rights, modern slavery and human trafficking.

A new edition of the Firm’s Responsible Business Report will be published on the Firm’s website in July 2024. A copy of the Firm’s July 2023 report is currently available on the website, with the theme for the report being “Transparency and Honesty”.

The report considers the Firm’s progress across our responsible business framework pillars of:

• Business Conduct;
• Sustainability;
• Pro Bono;
• Diversity, Equity and Inclusion; and
• Social Impact.

We are aware that these issues are important to our clients and suppliers, and we strive to be a firm which ’walks the talk’.

In 2023, the Firm became a signatory to the United Nations Global Compact, a pact between many of the world’s largest businesses to adopt sustainable and socially responsible policies.

In May 2024, the Firm provided its first report to the United Nations on its implementation of international human rights and labour standards.

The Firm’s Management Committee approved this statement on behalf of the members of Norton Rose Fulbright LLP on 11 June 2024.

View our 2023 Modern Slavery Act Statement
View our 2022 Modern Slavery Act Statement
View our 2021 Modern Slavery Act Statement
View our 2020 Modern Slavery Act Statement
View our 2019 Modern Slavery Act Statement
View our 2018 Modern Slavery Act Statement
View our 2017 Modern Slavery Act Statement
View our 2016 Modern Slavery Act Statement