LEGAL

Modern Slavery Statement

For the financial year ending 31 December 2024

Introduction

This statement sets out the actions of Pierson Ferdinand UK LLP and Pierson Ferdinand LLP (collectively, “PierFerd”) to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.

As part of the legal profession, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking.

PierFerd is absolutely committed to preventing slavery and human trafficking in its corporate activities and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational Structure and Supply Chains
PierFerd provides comprehensive litigation, corporate, finance, restructuring, employment and benefits, and intellectual property services in all major industries, helping clients address and anticipate challenges across vast and rapidly changing landscapes. Our teams of lawyers are organised into four (4) departments of practice across 23 offices, globally. Our practice areas include corporate, labor and employment, litigation and intellectual property.

Countries of Operation and Supply
PierFerd has 23 offices in North America and Europe, and is a registered limited liability partnership under the laws of the State of Delaware. PierFerd has approximately 180 individual partners with operations in various cities throughout the United States, as well as internationally. PierFerd’s international operations are structured as either branch offices or subsidiaries of wholly- owned companies. PierFerd is organised in the United Kingdom as a limited liability partnership authorised and regulated by the Solicitors Regulation Authority. PierFerd also, from time to time, works with local counsel in many jurisdictions in order to satisfy our clients’ requirements and instructions.

Risk Assessment to Identify High-Risk Activities or Jurisdictions
PierFerd has adopted a risk-based approach to assess against the risk of modern slavery within its supply chain. The criteria used in this approach includes the nature and location of the services provided and the identification of any red flag indicators.

Responsibility
Responsibility for PierFerd’s anti-slavery initiatives, including implementation and subsequent review of policies and the carrying out of risk assessments in respect of the risks associated with modern slavery lies with the General Counsel Team. The General Counsel Team will hold responsibility for carrying out any investigations and due diligence in relation to known or suspected instances of slavery and human trafficking involving PierFerd or its supply chain.

PierFerd has made training available to all its employees on modern slavery and will require compulsory completion on an annual basis, and has adopted a Modern Slavery Policy, setting out PierFerd’s approach to tackling the threat and risks.

Relevant Policies
PierFerd operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Whistleblowing Policy: PierFerd encourages all its workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of, PierFerd. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. PierFerd’s whistleblowing procedure is designed to make it easy for individuals to make disclosures, without fear of retaliation.

  • PierFerd Code of Business Conduct: PierFerd’s Code pf Business Conduct makes clear to employees the actions and behaviour expected of them when representing PierFerd. PierFerd strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.

  • Outsourcing Policy: PierFerd is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. PierFerd will work with suppliers to ensure that they meet the requirements of the legislation.

Due Diligence

PierFerd undertakes due diligence when considering taking on new suppliers and the process of review of its existing suppliers is ongoing. PierFerd’s due diligence and reviews include, or will include in the future, reviews:

  • mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;

  • evaluating the modern slavery and human trafficking risks of each new supplier;

  • reviewing on an annual basis all aspects of the supply chain based on the supply chain mapping;

  • taking steps to improve substandard suppliers’ practices, including providing advice to suppliers and if necessary requiring them to implement action plans;

  • conducting due diligence on all suppliers paying particular attention to their labour standards, compliance in general, and modern slavery and human trafficking policy in particular; and

  • invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Performance Indicators

PierFerd has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, PierFerd:

  • requires all staff to have completed training on modern slavery;

  • will develop a robust system for supply chain verification whereby PierFerd evaluates potential suppliers before they enter the supply chain; and

  • has reviewed its existing supply chain, evaluating all existing suppliers. This involved seeking declarations from all suppliers about their own strategy of combatting modern slavery and challenging any noncompliance.

Training
PierFerd requires all staff to complete training on modern slavery as a module within its wider risk and compliance training programme, which covers:

  • how to assess the risk of slavery and human trafficking, including resources and support available;

  • how to identify the signs of slavery and human trafficking;

  • what initial steps should be taken if slavery or human trafficking is suspected;

  • how to escalate potential slavery or human trafficking issues to the relevant parties within PierFerd;

  • what external help is available; and

  • what steps PierFerd should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from PierFerd’s supply chains.

Awareness-Raising Programme

A particular focus is on training those employees within business services who are regularly involved with PierFerd’s supply chain and Suppliers.

This statement has been approved by A. Michael Pierson, Co-Chairman, who will review and update it annually.