Anti-slavery and Human Trafficking Statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (Act) and constitutes the Fladgate LLP slavery and human trafficking statement for the financial year ending 31 March 2024.

The Act requires any commercial organisation in any sector, which supplies goods or services, and carries on a business or part of a business in the United Kingdom, and is above a specified total turnover, to produce and publish an annual slavery and human trafficking statement.

Fladgate LLP is committed to the prevention of the use of forced labour and has a zero tolerance policy for slavery and human trafficking.

Organisational Structure

Fladgate LLP is an internationally focused law firm, based in London, which provides a broad spectrum of legal services for businesses and individuals. Our firm comprises 320 partners, lawyers and support staff.

Our Policies on Slavery and Human Trafficking

Fladgate LLP will not use or allow the use of forced, compulsory labour, slavery, servitude or human trafficking in the course of its business. This includes sexual exploitation, securing services by force, threats or deception and securing services from children and vulnerable persons.

Our employment procedures guarantee that Fladgate LLP conducts appropriate checks on all staff to ensure they can legally work in the United Kingdom.

In addition, internal policies are reviewed regularly to ensure continued compliance with the Modern Slavery Act 2015.

Fladgate LLP operates the following policies which are relevant to the prevention of slavery and human trafficking in its operations:

• Anti-slavery and Human Trafficking Policy, which sets out the steps that the Firm is taking to prevent human trafficking and slavery within its business and its supply chain.
• Recruitment and selection policies, which include conducting checks on all staff to safeguard that they can legally work in the United Kingdom.
• Corporate Social Responsibility Policy, which is designed to ensure that Fladgate LLP is conducting its business responsibly.
• Whistleblowing policy, which encourages all of its employees to report any concerns related to the activities of the Firm. The Firm’s whistleblowing procedure is designed to ensure that any matter raised under this procedure will be investigated thoroughly, promptly and confidentially, and the outcome of the investigation reported back to the individual who raised the issue. Additionally, the policy guarantees that no one will be victimised for raising a matter under this procedure.

Due Diligence Processes for Slavery and Human Trafficking

As part of our initiative to identify and mitigate risk, we have put in place systems to:

• Identify and assess potential risk areas in our supply chains;
• Mitigate the risk of slavery and human trafficking occurring in our supply chains;
• Monitor potential risk areas in our supply chains; and
• Protect whistleblowers.

Supplier Adherence to Our Values and Ethics

To ensure contractors and those in our supply chain comply with our values and ethics, we have in place a rigorous supply chain compliance programme.

Under this policy, a material service supplier is any service supplier whose services in any twelve month period equates to or is expected to equate to over 0.25% of the Firm’s annual revenue.

Efforts are made to confirm that the Firm’s material service suppliers are as committed to the prevention of human trafficking and slavery as Fladgate LLP, and each material service supplier’s conduct is carefully considered when awarding or renewing business.

All material service suppliers for Fladgate LLP will be contacted to confirm their position with regards to human trafficking and slavery. They will be asked to provide information explaining the efforts made by them to avoid human trafficking and slavery within their organisations, and to confirm that they screen their own suppliers to ensure that they are also compliant with the Act.

Going forward, we will review our supply chain profile annually. Reviews with material service suppliers regarding human trafficking and slavery will also be conducted on an annual basis. If the responses are deemed unsatisfactory, our continued relationship with them will be determined by our Partnership Board and Head of Risk & Compliance. Similar assessments will be carried out when considering the modern slavery and human trafficking risks of each new material service supplier.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant partners and employees.

Performance Indicators

The key performance indicators (KPIs) we will use to measure how effective we are in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chain are as follows:

• completion of training of our policy by all relevant staff and partners;
• communication of our policy to our material service suppliers; and
• the satisfactory responses from our material service suppliers to confirm their understanding of and compliance with our expectations, and ensuring that these continue to be satisfactory.

Approval

This Statement, which is made pursuant to section 54(1) of the Act and constitutes our slavery and human trafficking statement for the financial year ended 31 March 2024, was approved by the Executive Board of Fladgate LLP on behalf of the members on 18 April 2024.

It will continue to be reviewed annually.