Modern Slavery Statement 2018

This statement is published on behalf of Ashurst LLP and its wholly-owned subsidiary, Ashurst Business Services Limited, each having a turnover in excess of £36 million and references to "Ashurst", "we", "us", "our" or the "firm" are to both and to the related entities that carry on the Ashurst business across the world.

Our approach

We are committed to achieving the highest standards of ethical behaviour in the conduct of our business and activities worldwide. We support and respect the protection of internationally proclaimed human rights and endeavour to make sure that Ashurst is not complicit in human rights abuses. To this end, we will not tolerate slavery or human trafficking or abusive or unfair treatment in any part of our own business or in any of our supply chains. We are generally, and in particular through our policies and practices in relation to procurement, human resources and corporate responsibility, committed to taking steps to ensure that slavery and human trafficking play no part in our own business or in our supply chains.

Policies and procedures that are in place and steps that we have taken are set out below.

Policies

We have a Global Corporate Responsibility Policy which, among other things, sets out our policy and approach on anti-slavery and human trafficking.

We have formal Global Procurement Policy and Guidelines and a formal Global Contracts Protocol. The Global Procurement Policy and Guidelines aim to ensure that all goods and services acquired on behalf of the firm are acquired in line with procurement best practice, on the most advantageous commercial terms, at the lowest risk profile and with proper consideration of the social, environmental and ethical impacts of such activity.

The Global Contracts Protocol aims to manage the firm's contractual risks by ensuring that appropriate due diligence is undertaken before entering into contracts. Due diligence requirements include a specific requirement to carry out due diligence in relation to slavery and enforced labour with all potential new vendors to Ashurst.

Procurement and supplier due diligence

Existing suppliers. Following on from activities in 2016 and 2017, 2018 saw the firm complete an audit of its key suppliers within the IT supply chain. Following a risk-based analysis, it was determined that there was an inherent risk of modern slavery and enforced labour in IT hardware third party supply chains. Subsequently, a questionnaire was submitted to the firm's key IT vendors requesting information on the processes undertaken by these suppliers to identify and mitigate the risk of modern slavery and enforced labour in their supply chain. The results of the audit were positive with all key IT suppliers reporting strong compliance models including site inspections, quality audits and independent accreditations.

It is the firm's priority to ensure our supplier management approach is continually reviewed. Over the coming year we plan to continue to develop our risk analysis and audit processes in relation to key third party suppliers.

New suppliers. Our standard bid invitation documentation asks due diligence questions of vendors to determine the steps they take to avoid or eliminate slavery and human trafficking from their supply chain. This forms one of the evaluation criteria behind our selection of new vendors.

It is a priority for the firm to ensure our robust selection criteria is implemented during the sourcing of any new supplier to identify potential modern slavery issues. While this has not occurred as yet, the existence of any slavery or human trafficking issue would mean a supplier would be immediately disqualified from the procurement process.

Training of staff involved in procurement

We have provided training for relevant staff who are likely to conduct procurement of goods and/or services for the firm or who manage our supplier relationships, with a view to stressing, amongst other things, Ashurst's zero tolerance stance on slavery and human trafficking as well as to reinforce the policies and procedures that we have in place.

Recruitment and welfare of our people

We are a leading law firm with more than 3,000 employees, partners and contractors working across Asia, Australia, Europe, the Middle East and North America. As a professional services firm, people are our most valuable asset at all levels of the business.

As part of our HR policies and procedures, we only use reputable recruitment firms and comply with all relevant local laws and regulations. We regularly review our global recruitment procedures and providers, as well as our arrangements for employee welfare and care. All employees are paid at least the minimum wage in the local jurisdiction and in London employees and contractors are paid the London Living Wage or above.

Approved by members of Ashurst LLP on 5 October 2018 and signed by Ben Tidswell, Designated Member on behalf of Ashurst LLP and Director on behalf of Ashurst Business Services Limited
5 October 2018