Modern Slavery Act Statement 2023

This statement is made on behalf of Norton Rose Fulbright LLP and Norton Rose Fulbright Services (together, the Firm) pursuant to Section 54 of the Modern Slavery Act 2015. It constitutes the Firm’s slavery and human trafficking statement for the financial year ending 30 April 2023.

As a legal service provider, the Firm recognises its responsibility to uphold the rule of law and respect human rights. The Firm operates in accordance with its 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 throughout its supply chain, including by engaging suppliers who respect human rights and share our commitment to high ethical standards.

This statement illustrates how we apply our Business Principles in practice and reflects our continued public commitment to confronting the use of forced, compulsory, trafficked or child labour within our own organisation and our supply chain.

Our Structure, Business and Supply Chains

Norton Rose Fulbright is a large co-ordinated international legal practice with multiple offices around the world. It comprises 5 member firms which, along with their subsidiaries and other affiliated entities, are joined via a Swiss verein.

The Firm has offices in Amsterdam, Athens, Bangkok, Beijing, Brussels, Casablanca, Dubai, 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.

The Firm provides legal services to business enterprises, governments and other public sector organisations. We are focused on 6 key industry sectors:

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

The Firm’s suppliers can be broadly categorised as follows:

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

Since June 2019, the Firm has incorporated its Additional Terms of Purchase for Goods and Services into contracts with suppliers. One of those additional terms requires suppliers to comply with the Firm’s Supplier Charter.

Our Supplier Charter sets out the Firm’s expectations of suppliers in the wider business ethics sense and is a key document in all new supplier relationships that the Firm forges. This includes a requirement that suppliers must conduct their business activities in a manner which respects human rights as set out in the United Nations Universal Declaration of Human Rights and the core conventions of the International Labour Organisation. It specifically requires 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 Firm’s Supplier Charter and Additional Terms of Purchase for Goods and Services are published on the Firm’s website. They were both updated in October 2023 and will be published imminently.

Members of staff and management involved in the procurement of goods and services (including members of our accounts payable team who manage payments to vendors) are trained to identify and monitor potential human rights issues and to use appropriate governance channels and protections in high-risk situations. These governance processes are being utilised successfully and the Firm has put measures in place to monitor compliance at multiple touch points, including vetting of suppliers by our Risk and Compliance team.

Policies

Human Rights

Our Human Rights Policy demonstrates our commitment to respecting internationally recognised human rights and sets out our expectations for the conduct of our staff and our business partners. The policy includes a commitment to constantly assess the impact of our business on human rights, including in our supplier procurement and client onboarding. It requires that we also take steps to support our clients’ respect for and understanding of human rights, through training and sharing best practices.

Implementation of the policy is supported by the provision of business and human rights (BHR) training to the Firm’s staff. This training comprises an 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. This training is mandatory for all staff of the Firm and is included as part of the induction programme for all new joiners.

Oversight and guidance of adherence to our policy is provided by specialists within the Firm’s Risk and Compliance team, as well as our Audit Committee, Social Impact and Sustainability Team and our Responsible Business Committee.

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 Employee Handbook, which comprises all employee related policies, was reviewed and updated in 2021 to take account of modern slavery issues.

Our Ethical Reporting “Report It” Policy encourages all members of staff to report known or suspected breaches of our ethical standards, including slavery, human trafficking, forced or child labour, as well as wider human rights related issues in accordance with the procedure set out in the policy.

It guarantees that any issue can be raised in confidence and refers to examples of forced, compulsory or trafficked labour as instances which we expect to be reported. This policy applies to all individuals working for the practice (whether in a permanent capacity or on a short-term basis) in any jurisdiction, including partners, avocats collaborateurs, employees, consultants, agency workers and contractors.

Due Diligence / Risk Assessment and Mitigation Processes

Employment

The Firm applies the highest possible standards in the recruitment and employment of our people.

As well as ensuring that the policies set out in the Employee Handbook are complied with, we:

ensure that all legal obligations are complied with in the recruitment and on-boarding process with a focus on an individual’s right to work in the relevant country in which they will be engaged;
conduct an appropriate level of due diligence on prospective employees prior to them joining the Firm, including a robust selection process and a number of other background checks (including taking up employment references), and on an annual basis for employees who are responsible for compliance with key internal risk management policies;
recruit, promote and develop our people on the grounds of merit and capability;
have a well-developed Diversity and Inclusion policy to ensure we have a diverse workforce and an inclusive culture, including affirmative action around the development of individuals from BAME backgrounds who otherwise meet our criteria on merit and capability; and
continue to support the Firm’s Respect in the Workplace policy.

All staff are expected to comply with our Global Practice Standards, Business Principles and any applicable regulatory requirements and professional codes of conduct. These expectations are reflected in our employment contracts and supported by the Firm’s policies, as set out in our Employee Handbook.

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

Our Clients

As a highly regulated law firm, we are required to conduct due diligence on our clients and identify our scope of engagement in accordance with applicable legislation and professional codes of conduct. The overriding principle is that we will not act for clients in circumstances where it is illegal or inappropriate to do so. The Firm has robust internal and external reporting procedures to deal with instances where illegality is suspected during the course of a matter.

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 record of, amongst other things, 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. We work with clients to resolve such issues, which 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.

Effectiveness Tracking

The Firm achieved its stated KPIs for 2022 / 2023. Specifically, we:

conducted a comprehensive BHR review and risk assessment of our Warsaw office;
updated the Firm’s Supplier Charter (and Additional Terms of Purchase for Goods and Services) which will be published on the Firm’s website;
reviewed and updated the Firm’s Human Rights Policy;
planned a comprehensive BHR due diligence review and risk assessment in 3 more of the Firm’s non-UK offices (1 in each of Asia, the Middle East and Europe); and
established a register of acknowledgment of the Firm’s Supplier Charter by suppliers.

We shall report on our performance against the following KPIs in our 2024 Modern Slavery Act statement:

completion of a further comprehensive BHR due diligence review and risk assessment in 3 of the Firm’s offices (1 in each of Asia, Middle East and Europe);
completion of an internal audit and review of the Firm’s vendor engagement, vetting and monitoring processes (which is currently underway as part of a broader vendor management project);
formal incorporation of modern slavery risks into the Firm’s Business Risk Assessment; 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.

As a broader commitment, the Firm also intends to further collaborate with its verein members on human rights and modern slavery related initiatives, monitoring and reporting.

Targeted Focus

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

The Firm published a Responsible Business Report in July 2023, a copy of which can be found on our website. The theme for the report is Transparency and Honesty. The report is designed to provide a “temperature check” on 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 December 2022, the Firm was awarded a gold medal by Ecovadis, a globally recognised assessment agency which rates business for their performance in key sustainability and responsible business categories, including labour and human rights.

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. As part of this commitment, the Firm will now report annually to the United Nations on its implementation of international human rights and labour standards.

MSA statement 2023