This statement is published on behalf of the DLA Piper Australia (National Partnership) (ABN 83 508 451 308) as the reporting entity pursuant to section 14 of the Modern Slavery Act 2018 (Cth) in respect of the financial year ended 30 April 2024.

Other entities that are associated with the reporting entity but do not pass the reporting threshold under the Act are DLA Piper Australia (Queensland Partnership) (ABN 63 446 756 774) and DLA Piper Australia Services Pty Ltd as trustee of the Australian Services Trust (ABN 22 612 749 221).

The DLA Piper National Partnership, the DLA Piper Queensland Partnership, DLA Piper Australia Services Pty Ltd and the Australian Services Trust are under common management, and operate the same policies, procedures, and controls. The partnership does not own or control any other entities.

References to "DLA Piper Australia," "we," "us," "our" or the "firm" are to these above-named entities. This statement identifies the steps that we have taken to mitigate the risk of modern slavery and human trafficking occurring within our operations or our supply chains. Where reference is made to “DLA Piper”, this refers to the part of the DLA Piper global law firm operating in Europe, the Middle East, Asia-Pacific and Africa.

Introduction

DLA Piper Australia is committed to the highest standards of professionalism, ethical behaviour and integrity in everything we do and to contributing to the wellbeing of communities around the world and has a zero-tolerance approach to all human rights abuses. In this we are committed to opposing modern slavery in all its forms, and we do not tolerate it either within our business itself or within our supply chain.

As a firm, we are committed to adhering to the following core values in all our dealings with our clients, our people, and our communities:

• Be supportive;
• Be collaborative;
• Be bold; and
• Be exceptional.

Our organisation structure and supply chain

DLA Piper Australia is part of DLA Piper, a global law firm operating through a number of separately constituted and regulated legal entities which provide legal and other client services in accordance with the relevant laws of the jurisdictions in which they respectively operate. DLA Piper Australia is a professional services business which predominantly employs professionally qualified and highly skilled people. Further information about the DLA Piper global law firm, including information on the countries in which we operate, can be found on our website by clicking here.

Our supply chain consists of goods and services procured to enable our people to deliver these services. Our relationships with sub-contractors, suppliers and their employees, business partners, agents and others working on their behalf (collectively "Third Parties") principally include professional services and consultancy, property, facilities management, human resources, information technology and marketing.

Working in collaboration with DLA Piper, our anti modern slavery strategy and due diligence process is developed and reviewed by a cross-functional Sustainable Procurement Working Group, including representatives from our Procurement, Property and Workplace, Responsible Business, and Office of the General Counsel teams. The Working Group is sponsored by our Chief Operating Officer and is accountable to the firm’s Executive and Board. A Procurement Assurance Committee is in place to review Procurement and Supplier related risks. The committee consists of members from Information Security, Procurement, Data Privacy, Legal, Responsible Business and Sustainability, Security & Insurance. Outputs of the Committee go to the Directors of Business & Service Delivery and Responsible Business. The DLA Piper Risk Management system is overseen by the International Risk Group and ultimately the Board Risk Committee.  We are further integrating sustainability risks into our enterprise risk management framework. This includes risks associated with our supply chain such as human rights and modern slavery.

There have been no material changes to our organisational structure or our supply chain during this reporting period.

Our policies in relation to slavery and human trafficking

DLA Piper’s policy framework includes a range of People and Procurement policies that outline our commitment to modern slavery and human trafficking risks in our business and supply chains. Relevant policies include:

• Human Rights & Modern Slavery Policy: makes explicit our commitment to the United Nations Guiding Principles on Business and Human Rights, endorsed by the International Bar Association. This Policy confirms our commitment to respect and support international human rights, and in particular to the International Bill of Rights and the International Labour Organisation's Declaration on the Fundamental Principles and Rights at Work. This policy is being reviewed and updated in 2024/25.
• International Inclusion Guidelines: encourages all our people to value diversity, actively promote inclusion, respect each person's individuality, and to ensure that no partner, employee, agency worker, contractor or self-employed consultant, receives less favourable treatment on the basis of colour, race, nationality, ethnic or national origins, sexuality or gender, disability, age or religion or belief. Our International Inclusion Guidelines are supported by country level policies tailored to the domestic environment, in Australia these include local policies dealing with anti-discrimination and harassment/sexual harassment.
• Ethics Policy: embodies the key ethical obligations of the firm and our people. It is pervasive in everything we do and in all our dealings, whether directly related to the provision of legal services or otherwise.
• Whistleblowing Policy: offers individuals a confidential mechanism for disclosing suspicions or knowledge of possible impropriety to protect the firm, its brand, people, and clients by delivering an early warning when something goes wrong. This includes matters pertaining to modern slavery.
• Incident Reporting Policy: offers individuals a mechanism for reporting breaches of firm policies and procedures, and errors, acts or omissions which result in breach of the legal or regulatory obligations of individuals or the firm. All our people have a personal obligation to report such incidents promptly and honestly when identified.
• Anti-bribery and Corruption Policy: sets out the firm's rules and what is expected of all our people. We expect the same standard of conduct from the firm's contractors and third-party service providers in all dealings on our behalf.
• Anti-facilitation of tax evasion Policy: sets out the firm’s commitment that it will not engage in tax evasion or the facilitation of tax evasion, and articulates the role and responsibility all our people have in preventing tax evasion and its facilitation. Where appropriate, suppliers are required to adopt the same standard of conduct when acting on the firm’s behalf.
• International Procurement Policy: defines the procurement processes for purchasing goods and services depending on the risk and value. This includes completion of the Due Diligence Questionnaire where specified spend and risk thresholds are met which contain questions on modern slavery.
• Sustainable Procurement Policy: outlines the firm’s approach to integrating the management of environmental, social and economic issues into our procurement management systems. The policy aligns with the Universal Declaration of Human Rights; UN Global Compact Ten Principles; UN Guiding Principles on Business and Human Rights and the Fundamental Conventions of the ILO. This policy has been updated to align more closely with ISO 20400 sustainable procurement standards and is published on our external website, click here.
• Supplier Code of Conduct: sets out our expectations of third parties providing goods and services to DLA Piper. It is aligned with the Universal Declaration of Human Rights; UN Global Compact Ten Principles; UN Guiding Principles on Business and Human Rights and the Fundamental Conventions of the ILO. This policy is published on our external website, Click here.

All of these policies have been made available to our people on our Intranet.

We comply with all applicable employment laws relating to employee terms and conditions.

Our international health and wellbeing strategy is overseen by an International Steering Committee made up of leaders from across the firm. The committee is sponsored by the Executive and supported by an international working group with representation from all regions, ensuring we take cultural differences into consideration when setting our approach. The Managing Partner of DLA Piper Australia is on the Steering Committee.

Our vision is to create a firmwide culture where work and great health and wellbeing go hand in hand. Our refreshed health and wellbeing strategy has four key pillars: physical, emotional, social and financial health, and focusses on three key areas:

• Promotion of greater wellbeing at work for all: we raise awareness of wellbeing issues to help reduce stigma and make it easier for our people to reach out for help. We encourage open discussions about health and wellbeing in the workplace and have resources and policies in place to support. As signatories of the Mindful Business Charter, we encourage sustainable working practices. We run internal campaigns and hold mental health events that shine a spotlight on the experiences of our people.
• Provision of support and care for our colleagues: to ensure all our people are supported, we work to embed a diverse variety of resources, skills and good health and wellbeing practices throughout our firm. We do this through initiatives such as our SPEAK Ambassador Programme, which aims to create an environment where colleagues feel comfortable talking about mental health issues in the workplace. With MyCare, our international EAP service, we provide a range of free, confidential health and wellbeing services for our people and their families. Through digital tools such as Unmind we empower people to take responsibility for their own wellbeing.
• Prevention of health and wellbeing issues: as well as providing reactive support, we are committed to preventing health and wellbeing issues before they happen. This includes using internal data to understand and track the diverse needs of our colleagues, ensuring that health and wellbeing considerations are embedded in key business processes, and introducing policies and guidelines (such as WorksmartFlex) to help colleagues find the right work/life balance. We work with clients and across professional and regulatory bodies to collectively identify health and wellbeing issues in our industry and explore new ways of working to address them.

DLA Piper Australia is also a founding member of the Corporate Mental Health Alliance Australia, an alliance of Australian businesses dedicated to providing mentally healthy workplaces for our people.

Strategy and supply chain due diligence

DLA Piper Australia expects our suppliers to adopt the same high standards that we adhere to and have fair employment practices. These standards are reflected in the policies we share with our suppliers and ask them to commit to as part of a tender process, in the case of significant suppliers to the business. They include our Human Rights and Modern Slavery Policy and Supplier Code of Conduct and specifically deal with modern slavery by including, amongst other things, that our suppliers ensure that employment is freely chosen, child labour shall not be used, minimum wages are paid, and working hours are not excessive.

When appropriate, we continue to use standardised supplier contract templates, in which consideration of Modern Slavery risk and mitigations have been embedded and/or ensure that our Customer Policies schedule (including Modern Slavery Policy) is attached to suppliers’ agreements.

In the last 12 months, we started an ongoing risk assessment of our supply chain while referring to available research published by expert civil society organisations. This research will be carried out on a bi-annual basis to ensure our understanding of our supply chain and what risks it presents remain current.

We use feedback from our process to drive ongoing improvement in our supplier onboarding process. This aims to:

• Create a more robust process for suppliers, particularly those in geographies and industries with a higher risk of human rights violations; and
• Centralise data on our new supplier management platform to better assess suppliers on topics including those related to human rights.

The Sustainable Procurement Working Group will continue the risk assessment while implementing the necessary improvements to the supplier onboarding process, while the Procurement Assurance Committee will monitor any identified third-party risks.

The objective is to equip the firm to mitigate potential risks throughout the supplier engagement lifecycle from on-boarding through to performance improvement. We continue to gain further visibility across our supply chain, regularly review our data sets, risk register, and ensure the continuous improvement of our approach to supply chain and modern slavery risk management.

The DLA Piper whistleblowing policy, procedure, and processes has been updated and relaunched, and a third party supported whistleblowing portal has been made available to all our people and to external and third-party stakeholder through the firm’s website.   A project is underway in 2024/25 to embed the firm’s whistleblowing policy procedure in Australia, which will be supported by tailored communication and training.

Risk assessment and management

Our primary method of assessing and addressing the risk of modern slavery is through a supply chain ESG risk assessment.

DLA Piper Australia has identified a higher risk of modern slavery in connection with suppliers delivering the following services: building repairs, cleaning, catering, consumables, couriers, office fit-out, security and taxis. We also assess and manage the risk of modern slavery pre-contract with each supplier, and on an ongoing basis during contract management and review:

• Pre-contract: as part of our Supplier Management Platform roll out, our suppliers will be screened against various country rating areas including Global Slavery Index. Also, depending on the spend and risk threshold, suppliers will be issued with the Engagement Form and Due Diligence Questionnaire which includes questions designed to identity modern slavery risk and establish what measures potential suppliers have in place. This information is used to decide what mitigating measures are required to manage our risk.
• Contract management and review: Our standard contract terms contain a clause by which we ask suppliers to commit to respecting and supporting international human rights and undertake that they will comply with their obligations under the Modern Slavery Act or any other similar legislation as well as any of our policies that are shared with them. We also reserve the right to terminate agreements with immediate effect when the supplier commits a material breach.

For contracts where the risk of modern slavery is heightened, we will include requirements for our suppliers to have in place:

• a policy commitment prohibiting the use of modern slavery that is approved at board or senior-management level, which sets out its expectations on personnel and suppliers/subcontractors;
• risk screening and diligence procedures to identify and monitor the risk of modern slavery;
• corrective action plans to investigate, respond to and mitigate any identified risk of modern slavery;
• training on modern slavery risk identification and management; and
• a reporting and/or whistleblowing mechanism for personnel and third parties to report any actual or suspected risk of modern slavery.

Where relevant, we also require that some suppliers pass these commitments down to their own suppliers and subcontractors.

In relation to supplier engagement, the frequency of meetings is dictated by a number of factors, including consideration of the risks posed by involvement in modern slavery. Where possible and appropriate, we try to include in our contracts a contractual right to audit our suppliers. We also receive independent feedback on our performance from certain key clients who audit their relationship with us as their suppliers.

Through ongoing supplier management routines, supplier engagement, and at break points such as contract renewal, the effectiveness of the steps taken to mitigate risk are re-assessed and changed or enhanced where necessary.

There have been no material changes to our principal third-party suppliers, who continue to be businesses which supply services related to the running of our premises (such as landlords, building managers, cleaners, caterers, and security) and supply of the IT equipment, stationery and consumables needed to deliver our legal services to clients.

We recognise that the consequences of global warming and migration, the ongoing situation in Ukraine and the Middle east, and other geopolitical factors, have and will continue to impact the risk of modern slavery across a range of sectors, as does the economic uncertainty and instability these have created. We have undertaken and will continue to update such assessments and steps as necessary to address these and other emerging risks.

Monitoring and Performance indicators

The DLA Piper cross-functional Sustainable Procurement Working Group holds quarterly meetings to measure the effectiveness of our strategy and continuously review our priorities and performance. The following Key Performance Indicators are used to monitor the effectiveness of our risk management processes, our target for these KPIs is 85%:

• the percentage of Critical suppliers that have agreed to our Supplier Code of Conduct;
• the percentage of Critical suppliers who have social or environmental objectives in place; and
• the percentage of our people with procurement responsibilities across all locations who have received training on the Modern Slavery Act/sustainable procurement.The completion rate at the date of this statement was 83%.

These are annual targets reviewed at the end of each reporting period.

We are in the process of implementing an end-to-end supplier relationship management platform which will, moving forward, deliver improved supplier information and supply accurate data on our performance against the first two KPIs.

Reporting concerns

Our values promote an open and collaborative culture in which people can speak up safely and in confidence. The firm encourages its people to report concerns to managers, supervisors, and to human resources, alongside which it has two more formal reporting mechanisms in place:

• Incident reporting: to report errors or omissions which result in failures to comply with the firm’s policies and procedures, or which could result in a breach of legal or regulatory obligations; and
• Whistleblowing: a confidential mechanism for individuals to disclose suspicions of impropriety or wrongdoing.
• Disclosures related to modern slavery can be made via any of the above mechanisms in confidence.

Training

Since 2020 all colleagues with procurement responsibilities or who are supplier relationship managers for key suppliers on behalf of DLA Piper Australia, within Australia and across DLA Piper, are required to periodically complete our Modern Slavery Act: Practical Steps for Procurement training module. The completion rate for the most recent round of training can be found in the section on monitoring and performance indicators.

At the start of 2024, we introduced a new training module titled Modern Slavery Act: Raise Your Awareness which colleagues in all our business services teams are required to complete. The training covers the reality of modern slavery today, the role of DLA Piper, and how to spot signs of slavery in our supply chain. The completion rate for the most recent round of training was 78% at the date of this statement.

During 2024 we have rolled out anti-bribery and corruption refresher training to everyone in Australia, and throughout DLA Piper.  The completion rate for our people in Australia at the date of this statement was 76%.

The topic of sustainable procurement is integrated into the firm’s new starter induction presentation for staff involved in procurement. All DLA Piper Australia’s people are required to undertake mandatory training on policies relevant to their roles and responsibilities, and assurances on compliance is obtained via the firm’s annual Compliance & Professional Indemnity Declaration.

Responsible Business

DLA Piper has adopted Sustainability & ESG as a strategic priority for the firm, and Impactvise has rated us the number one law firm in the world for ESG performance out of over 1000 law firms globally.

We have a responsible ethos and care about our people, our communities, and the environment, and uphold high governance and ethical standards. As a firm, we actively engage with our people, our clients, and our communities to understand evolving expectations.

DLA Piper’s Sustainability and ESG Steering Committee is the primary governance body at the firm on sustainability and ESG. It reports to the Managing Director of Sustainability and provides an advisory, facilitating and coordinating role to the Managing Partner and the Executive, who are in turn accountable to our International Board for our sustainability & ESG performance. The Committee is chaired by the International Head of Sustainability and ESG. It is composed of regional representatives from across the firm as well as core support function leads.

We also have a Reconciliation Action Plan which reflects our dedication to promoting Indigenous rights and fostering strong partnerships with Aboriginal and Torres Strait Islander communities. By integrating ethical supply chain practices, providing pro bono legal services, and engaging in community led initiatives, we are supporting the mitigation of modern slavery risks while empowering Aboriginal and Torres Strait Islander businesses.

DLA Piper Australia is an executive member of the Australian Legal Sector Alliance (AusLSA), an industry-led association working collaboratively to promote best practice sustainability commitments and performance across the legal sector.

AusLSA runs a Modern Slavery Co-Lab which is a facilitated group of sessions that enables law firms like DLA Piper to share the progress and challenges of their modern slavey programs and build their skills and capacity of to reduce the risks and impacts of Modern Slavery in their supply chains.

DLA Piper has been a signatory to the UN Global Compact (UNGC) 10 Principles since 2013. We have aligned our strategies and operations with the universal principles on human rights, labour, anti-corruption, and the environment. We publish an annual Sustainability Report, to reaffirm our commitment to these principles and demonstrate our progress in working to achieve them. Since the Sustainable Development Goals (SDGs) were agreed in 2015, we also embraced them as a guiding framework for achieving positive impact. Our latest Sustainability Report is published on our website, further information here.

Management approval

The Board of DLA Piper Australia approved this statement on behalf of the Partners on 8^th November 2024 and is signed by Amber Matthews, Managing Partner, Australia.

Amber Matthews, Managing Partner, DLA Piper Australia

This statement is published on behalf of DLA Piper International LLP and DLA Piper UK LLP pursuant to Section 54(1) of the Modern Slavery Act 2015 in respect of the financial year ended 30 April 2024. References to "DLA Piper," "we," "us," "our" or the "firm" are to these named entities.

Introduction

DLA Piper is committed to the highest standards of professionalism, ethical behaviour and integrity in everything we do, to contributing to the wellbeing of communities around the world and has a zero-tolerance approach to all human rights abuses. In this we are committed to opposing modern slavery in all its forms, and we do not tolerate it either within our business or within our supply chain.

As a firm, we are committed to adhering to the following core values in all our dealings with our clients, our people, and our communities:

• Be supportive;
• Be collaborative;
• Be bold; and
• Be exceptional.

Our organisation structure and supply chain

DLA Piper International LLP and DLA Piper UK LLP are part of DLA Piper, a global law firm operating through a number of separately constituted and regulated legal entities which provide legal and other client services in accordance with the relevant laws of the jurisdictions in which they respectively operate. DLA Piper is a professional services business which predominantly employs professionally qualified and highly skilled people. Further information about the DLA Piper global law firm, including information on the countries in which we operate, can be found on our website by clicking here.

Our supply chain consists of goods and services procured to enable our people to deliver these services. Our relationships with sub-contractors, suppliers and their employees, business partners, agents and others working on their behalf (collectively "Third Parties") principally include professional services and consultancy, property, facilities management, human resources, information technology and marketing.

Our anti-modern slavery strategy and diligence processes are developed and reviewed by a cross-functional Sustainable Procurement Working Group, including representatives from our Procurement, Property and Workplace, Responsible Business, and Office of the General Counsel teams. The Working Group is sponsored by our Chief Operating Officer and is accountable to the firm's Executive and Board. A Procurement Assurance Committee is in place to review Procurement and Supplier related risks. The committee consists of members from Information Security, Procurement, Data Privacy, Legal, Responsible Business and Sustainability, Security & Insurance. Outputs of the Committee go to the Directors of Business & Service Delivery and Responsible Business. Our Risk Management system is overseen by our International Risk Group and ultimately the Board Risk Committee. We are further integrating sustainability risks into our enterprise risk management framework. This includes risks associated with our supply chain such as human rights and modern slavery.

There have been no material changes to our organisational structure or our supply chain during this reporting period.

Our policies in relation to slavery and human trafficking

Our policy framework includes a range of People and Procurement policies that outline our commitment to preventing modern slavery and human trafficking risks in our business and supply chain. Relevant policies include:

• Human Rights & Modern Slavery Policy: makes explicit our commitment to the United Nations Guiding Principles on Business and Human Rights, endorsed by the International Bar Association. This Policy confirms our commitment to respect and support international human rights, and in particular to the International Bill of Rights and the International Labour Organisation's Declaration on the Fundamental Principles and Rights at Work. This policy is being reviewed and updated in 2024/25.
• International Inclusion Guidelines: encourages all our people to value diversity, actively promote inclusion, respect each person's individuality, and to ensure that no partner, employee, agency worker, contractor or self-employed consultant, receives less favourable treatment on the basis of colour, race, nationality, ethnic or national origins, sexuality or gender, disability, age or religion or belief. Our International Inclusion Guidelines are supported by relevant country level policies.
• Ethics Policy: embodies the key ethical obligations of the firm and our people. It is pervasive in everything we do and in all our dealings, whether directly related to the provision of legal services or otherwise.
• Whistleblowing Policy: offers individuals a confidential mechanism for disclosing suspicions or knowledge of possible impropriety to protect the firm, its brand, people, and clients by delivering an early warning when something goes wrong. This includes matters pertaining to modern slavery.
• Incident Reporting Policy: offers individuals a mechanism for reporting breaches of firm policies and procedures, and errors, acts or omissions which result in breach of the legal or regulatory obligations of individuals or the firm. All our people have a personal obligation to report such incidents promptly and honestly when identified.
• Anti-bribery and Corruption Policy: sets out the firm's rules and what is expected of all our people. We expect the same standard of conduct from the firm's contractors and third-party service providers in all dealings on our behalf.
• Anti-facilitation of tax evasion Policy: sets out the firm's commitment that it will not engage in tax evasion or the facilitation of tax evasion, and articulates the role and responsibility all our people have in preventing tax evasion and its facilitation. Where appropriate, suppliers are required to adopt the same standard of conduct when acting on the firm's behalf.
• International Procurement Policy: defines the procurement processes for purchasing goods and services depending on the risk and value. This includes completion of the Due Diligence Questionnaire where specified spend and risk thresholds are met which contain questions on modern slavery.
• Sustainable Procurement Policy: outlines the firm's approach to integrating the management of environmental, social, and economic issues into our procurement management systems. The policy aligns with the Universal Declaration of Human Rights; UN Global Compact Ten Principles; UN Guiding Principles on Business and Human Rights and the Fundamental Conventions of the ILO. This policy has been updated to align more closely with ISO 20400 sustainable procurement standards and is published on our external website, further information here.
• Supplier Code of Conduct: sets out our expectations of third parties providing goods and services to DLA Piper. It is aligned with the Universal Declaration of Human Rights; UN Global Compact Ten Principles; UN Guiding Principles on Business and Human Rights and the Fundamental Conventions of the ILO. This policy is published on our external website, further information here.

All these policies have been made available to all our people on our Intranet.

We comply with all applicable employment law relating to employee terms and conditions, including pay, and have been accredited as a UK Living Wage Employer by the Living Wage Foundation.

Our international health and wellbeing strategy is overseen by an International Steering Committee made up of leaders from across the firm. The committee is sponsored by the Executive and supported by an international working group with representation from all regions, ensuring we take cultural differences into consideration when setting our approach.

Our vision is to create a firmwide culture where work and great health and wellbeing go hand in hand. Our refreshed health and wellbeing strategy has four key pillars: physical, emotional, social, and financial health, and focuses on three key areas:

• Promotion of greater wellbeing at work for all: we raise awareness of wellbeing issues to help reduce stigma and make it easier for our people to reach out for help. We encourage open discussions about health and wellbeing in the workplace and have resources and policies in place to support. As signatories of the Mindful Business Charter, we encourage sustainable working practices. We run internal campaigns and hold mental health events that shine a spotlight on the experiences of our people.
• Provision of support and care for our colleagues: to ensure all our people are supported we work to embed a diverse variety of resources, skills and good health and wellbeing practices throughout our firm. We do this through initiatives such as our SPEAK Ambassador Programme, which aims to create an environment where colleagues feel comfortable talking about mental health issues in the workplace. With MyCare, our international EAP service, we provide a range of free, confidential health and wellbeing services for our people and their families. Through digital tools such as Unmind we empower people to take responsibility for their own wellbeing.
• Prevention of health and wellbeing issues: as well as providing reactive support, we are committed to preventing health and wellbeing issues before they happen. This includes using internal data to understand and track the diverse needs of our colleagues, ensuring that health and wellbeing considerations are embedded in key business processes, and introducing policies and guidelines (such as WorksmartFlex) to help colleagues find the right work/life balance. We work with clients and across professional and regulatory bodies to collectively identify health and wellbeing issues in our industry and explore new ways of working to address them.

The “New Deal”, introduced in 2022 has been further embedded, and enhanced by the addition of a "Workation" scheme. This offers our people more flexibility in how and where they work, meaningful recognition and feedback, and investment in careers and ambitions. This is being delivered under three principles: we trust you, we value you, and we invest in you.

Strategy and supply chain due diligence

DLA Piper expects our suppliers to adopt the same high standards that we adhere to and have fair employment practices. These standards are reflected in the policies we share with our suppliers and ask them to commit to as part of a tender process. They include our Human Rights and Modern Slavery Policy and Supplier Code of Conduct and specifically deal with modern slavery by including, amongst other things, that our suppliers ensure that employment is freely chosen, child labour shall not be used, living wages are paid, and working hours are not excessive.

When appropriate, we continue to use standardised supplier contract templates, in which consideration of Modern Slavery risk and mitigations have been embedded and/or ensure that our Customer Policies schedule (including Modern Slavery Policy) is attached to suppliers’ agreements.

We use feedback from our process to drive ongoing improvement in our supplier onboarding process. This aims to:

• Create a more robust process for suppliers, particularly those in geographies and industries with a higher risk of human rights violations; and
• Centralise data on our new supplier management platform to better assess suppliers on topics including those related to human rights.

The Sustainable Procurement Working Group will continue the risk assessment while implementing the necessary improvements to the supplier onboarding process, while the Procurement Assurance Committee will monitor any identified third-party risks.

The objective is to equip the firm to mitigate potential risks throughout the supplier engagement lifecycle from on-boarding through to performance improvement. We continue to gain further visibility across our supply chain, regularly review our data sets and risk register, and ensure the continuous improvement of our approach to supply chain and modern slavery risk management.

The project to embed the firm’s whistleblowing policy, procedure, and processes, has been completed across the UK and Europe, and is compliant with applicable law and regulation in each country where we do business. All our people in those geographies have been targeted with training on whistleblowing. The third party supported whistleblowing portal has been made available to all our people and to external and third-party stakeholder through the firm’s website. A project is underway in 2024/25 to embed the firm’s whistleblowing policy procedure and processes across the Middle East, Africa, Asia, and Australia, and to ensure in complies with applicable law and regulation in all countries where we do business. Training will be rolled out to our people in those geographies as part of the project.

Risk assessment and management

Our primary method of assessing and addressing the risk of modern slavery across our reporting entities is through a supply chain ESG risk assessment. The assessment is risk based and targeted to identify "higher risk" suppliers. We also assess and manage the risk of modern slavery pre-contract with each supplier, and on an ongoing basis during contract management and review:

• Pre-contract: as part of our Supplier Management Platform roll out, our suppliers will be screened against various country rating areas including Global Slavery Index. Also, depending on the spend and risk threshold, suppliers will be issued with the Engagement Form and Due Diligence Questionnaire which includes questions designed to identity modern slavery risk and establish what measures potential suppliers have in place. This information is used to decide what mitigating measures are required to manage our risk.
• Contract management and review: Our standard contract terms contain a clause by which we ask suppliers to commit to respecting and supporting international human rights and undertake that they will comply with their obligations under the Modern Slavery Act or any other similar legislation as well as any of our policies that are shared with them. We also reserve the right to terminate agreements with immediate effect when the supplier commits a material breach.

For contracts where the risk of modern slavery is heightened, we will include requirements for our suppliers to have in place:

• a policy commitment prohibiting the use of modern slavery that is approved at board or senior-management level and which sets out its expectations on personnel and suppliers/subcontractors;
• risk screening and diligence procedures to identify and monitor the risk of modern slavery;
• corrective action plans to investigate, respond to and mitigate any identified risk of modern slavery;
• training on modern slavery risk identification and management; and
• a reporting and/or whistleblowing mechanism for personnel and third parties to report any actual or suspected risk of modern slavery.

Where relevant, we also require that some suppliers pass these commitments down to their own suppliers and subcontractors.

In relation to supplier engagement, the frequency of meetings is dictated by a number of factors, including consideration of the risks posed by involvement in modern slavery. Where possible and appropriate, we include in our contracts a contractual right to audit our suppliers. We also receive independent feedback on our performance from certain key clients who audit their relationship with us as their suppliers.

Through ongoing supplier management routines, supplier engagement, and at break points such as contract renewal, the effectiveness of the steps taken to mitigate risk are re-assessed and changed or enhanced where necessary.

There have been no material changes to our principal third-party suppliers, who continue to be businesses which supply services related to the running of our premises (such as landlords, business managers, cleaners, caterers, and security) and supply of the IT equipment, stationery and consumables needed to deliver our legal services to clients.

Similarly, those areas of our business and supply chain that carry a potential risk of modern slavery remain predominantly those which involve suppliers providing goods and services outside the UK, specifically Africa, the Middle East, and Southeast Asia.

We recognise that the consequences of global warming and migration, the ongoing situation in Ukraine and the Middle east, and other geopolitical factors, have and will continue to impact the risk of modern slavery across a range of sectors, as does the economic uncertainty and instability these have created. We have undertaken and will continue to update such assessments and steps as necessary to address these and other emerging risks.

Monitoring and performance indicators

Our cross-functional Sustainable Procurement Working Group holds quarterly meetings to measure the effectiveness of our strategy and continuously review our priorities and performance. The following Key Performance Indicators are used to monitor the effectiveness of our risk management processes, our target for these KPIs is 85%:

• the percentage of Critical suppliers that have agreed to our Supplier Code of Conduct;
• the percentage of Critical suppliers who have social or environmental objectives in place; and
• the percentage of our people with procurement responsibilities across all locations who have received training on the Modern Slavery Act/sustainable procurement. The completion rate at the date of this statement was 83%.

These are annual targets reviewed at the end of each reporting period.

We are in the process of implementing an end-to-end supplier relationship management platform which will, moving forward, deliver improved supplier information and supply accurate data on our performance against the first two KPIs.

Reporting concerns

Our values promote an open and collaborative culture in which people can speak up safely and in confidence. The firm encourages its people to report concerns to managers, supervisors, and to human resources, alongside which it has two more formal reporting mechanisms in place:

• Incident reporting: to report errors or omissions which result in failures to comply with the firm's policies and procedures, or which could result in a breach of legal or regulatory obligations; and
• Whistleblowing: a confidential mechanism for individuals to disclose suspicions of impropriety or wrongdoing.

Disclosures related to modern slavery can be made via any of the above mechanisms in confidence.

Training

Since 2020 all colleagues with procurement responsibilities or who are supplier relationship managers for key suppliers are required to periodically complete our Modern Slavery Act: Practical Steps for Procurement training module. The completion rate for the most recent round of training can be found in the section on monitoring and performance indicators.

At the start of 2024, we introduced a new training module titled Modern Slavery Act: Raise Your Awareness which colleagues in all our business services teams are required to complete. The training covers the reality of modern slavery today, the role of DLA Piper, and how to spot signs of slavery in our supply chain. The completion rate for the most recent round of training was 78% at the date of this statement.

During 2024 we have rolled out anti-bribery and corruption refresher training to everyone in the United Kingdom and the DLA Piper businesses throughout Europe, Middle East, Asia, Africa, and Australia. The completion rate for our people in the United Kingdom at the date of this statement was 82%.

In support of our firm’s whistleblowing strategy, in 2024 we have rolled out training to all our people in the UK and Europe. The completion rate for our people in the United Kingdom at the date of this statement was 81%.

The topic of sustainable procurement is integrated into the firm's new starter induction presentation in the UK and Ireland. All our people are required to undertake mandatory training on policies relevant to their roles and responsibilities, and assurances on compliance is obtained via the firm's annual Compliance & Professional Indemnity Declaration.

Responsible business

DLA Piper has adopted Sustainability & ESG as a strategic priority for the firm, and Impactvise has rated us the number one law firm in the world for ESG performance out of over one thousand law firms globally.

We have a responsible ethos and care about our people, our communities, the environment, and uphold high governance and ethical standards. As a firm, we actively engage with our people, our clients and our communities to understand evolving expectations.

DLA Piper’s Sustainability and ESG Steering Committee is the primary governance body at the firm on sustainability and ESG. It reports to the Managing Director of Sustainability and provides an advisory, facilitating and coordinating role to the Managing Partner and the Executive, who are in turn accountable to our International Board for our sustainability & ESG performance. The Committee is chaired by the International Head of Sustainability and ESG. It is composed of regional representatives from across the firm as well as core support function leads.

DLA Piper has been a signatory to the UN Global Compact (UNGC) 10 Principles since 2013. We have aligned our strategies and operations with the universal principles on human rights, labour, anti-corruption, and the environment. We publish an annual Sustainability Report, to reaffirm our commitment to these principles and demonstrate our progress in working to achieve them. Since the Sustainable Development Goals (SDGs) were agreed in 2015, we also embraced them as a guiding framework for achieving positive impact. Our latest Sustainability Report is published on our website, further information here.

Board approval

The DLA Piper Board approved this statement on behalf of the members on 31st October 2024.

Simon Levine, Managing Partner