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GT's UK Modern Slavery Act 2015 Statement

This statement is published on behalf of Greenberg Traurig, LLP (a UK registered entity), pursuant to section 54 of the UK Modern Slavery Act 2015 (the “Act”). It constitutes our modern slavery and human trafficking statement for the financial year ending 31 March 2022.

Greenberg Traurig, LLP (“GT”) is the London office of the global firm Greenberg Traurig, with over 120 lawyers providing legal services to a broad range of clients in the UK and across the globe.

GT is committed to the highest standards of ethical, moral and legal business conduct. GT has a zero-tolerance approach to all forms of slavery, servitude, forced or compulsory labour and human trafficking (collectively referred to as “Modern Slavery”). To that end, we have in place practices that we continue to develop, to combat all forms of Modern Slavery within our supply chains or in any part of our business.

GT respects human rights standards and promotes fair reward and recognition of diversity, inclusion and equal opportunity in all employee dealings, including decisions on hiring, remuneration, training and development.

Our Anti-Modern Slavery Policy

Our Anti-Modern Slavery Policy (our “Policy”) reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to seek to ensure Modern Slavery is not taking place in our supply chains.

Our Policy requires anyone who becomes aware of or suspects Modern Slavery in our business or supply chains to report it and assures them of appropriate confidentiality. The Policy applies to all GT personnel. We are taking steps to ensure that all GT personnel are aware of the Policy and their obligations under the Policy.

Our Supply Chain Relationships

Our business is predominantly office-based and we have a relatively simple and limited supply chain supporting these operations. We engage the professional services of barristers and other specialist advisors or experts to assist us in the provision of our legal services. We may also need to engage suppliers for the provision of goods and services including in the areas of recruitment, use of temporary staff, document management and review providers, technology solutions and other support services directly linked to the provision of legal advice and to support the business. We may also require project-specific support (for example, in connection with an office move) in addition to everyday operational support, including facilities management services – catering, cleaning, pest control and maintenance of equipment.

Supplier Due Diligence

Our Policy is supplemented by appropriate due diligence to ensure that risks arising from Modern Slavery in relation to our suppliers are identified and managed.

The process by which we identify and select our suppliers differs depending on the nature of the services and products they are providing and may be influenced by the length and value of the contract. A risk-based approach is used to determine the level of due diligence appropriate to be undertaken. None of our supplier relationships are considered to be high risk and therefore no enhanced due diligence steps have been taken to date.

We are currently evaluating our due diligence systems and controls for the procurement of new suppliers or the renewal of existing supplier contracts. In particular, we are seeking to ensure that our contractual arrangements with new suppliers include an express term relating to compliance with the Act.

Risk & Effectiveness

As a regulated provider of legal services and employer of predominantly professionally qualified and highly skilled people, the risk of Modern Slavery within our business is considered low. We apply robust policies and procedures in relation to employment screening (including work eligibility checks) and employment conditions.

We maintain an up-to-date list of all suppliers, none of which has been identified as having a high risk of Modern Slavery.

To date, we have not identified any occurrence of Modern Slavery in our supply chain, nor have we identified any risks of Modern Slavery that we have not been able to resolve through additional due diligence or engagement with the supplier.

Training

We are committed to ensuring that all GT personnel involved in procurement have the knowledge and understanding to recognise the key issues and risks relating to Modern Slavery and how these are to be addressed in our supply chain. GT requires all new staff to complete compliance induction training, which equips employees with the skills necessary to identify the signs of wrongdoing and to report it. We have recently introduced a software tool to allow our personnel to report ethical misconduct anonymously.

Concluding Statement

We will continue to review our policies, processes and controls to ensure they are operating effectively and proportionately to the risks faced within our supply chain. We will continue to make efforts to identify any significant risks in our business and supply chain and implement any actions appropriate or necessary directly with suppliers.

This statement has been approved by the Management Committee of Greenberg Traurig, LLP on behalf of its members.

October 2022