Modern slavery statement

Modern Slavery Annual Transparency Statement

(in compliance with the section 54 (Transparency in Supply Chains) of the Modern Slavery Act 2015)

1) Organisation Structure & Supply Chains

Corporate Structure

Gowling WLG is an international, sector-focused law firm. As a "people first" firm, our commitment to responsible business practices is guided by our core principles. We strive to minimize our environmental impact, encourage ethical working practices, strengthen our communities, support the professional and personal growth of our people, and provide pro bono services to those in greatest need. As part of this, we are working to combat risks of modern slavery by implementing policies and practices that work to ensure ethical standards are upheld throughout our operations and supply chains.

Gowling WLG (UK) LLP is a limited liability partnership registered in England and Wales (registered number OC304378). We are a global provider of legal services and operate from offices in the UK, Belgium, China, France, Germany, and the U.A.E. Along with Gowling WLG (Canada) LLP we are members of Gowling WLG International Limited, a company limited by guarantee registered in England. However, Gowling WLG (Canada) LLP and Gowling (UK) LLP operate and carry on business as independent and autonomous entities and Gowling WLG International Limited does not provide legal or other services to clients. For more information on our legal structure, please see here.

Gowling WLG (UK) LLP has annual turnover of £225m* and average number of employees of 1,209*.

Nature of our Supply Chain

As a legal services provider, we offer advice across numerous practice areas to a diverse, multinational client base. Our business is supported by a broad supply chain, which forms the foundation for delivering these services, including small and medium enterprises (SMEs) to global corporations. Our primary supplier categories include property and facilities (e.g. rent, rates, catering, cleaning, security, and maintenance), office supplies, support services (e.g. reprographics, transcription services, printing, and scanning), and technology (e.g. laptops, servers, printers).

To demonstrate the extensive range of our supply chain, it also includes contracted services for knowledge management, office design, fit out and maintenance, recruitment, temporary staff provision, cleaning and catering, as well as document production.
Our supply chain is primarily based in the UK, however, due to the range of products and services we require and the location of offices in our multinational business, we procure from many jurisdictions.

We have, to date, identified that certain categories of suppliers give rise to higher risk of forced labour for example: facilities management and the manufacture of IT hardware and are focussing on these in the first instance to better understand the risk and potential mitigations.

2) Policies in relation to slavery and human trafficking

We are committed to preventing acts of modern slavery and human trafficking from occurring within both our business and our supply chain. We expect all our suppliers to conduct their business in a lawful and ethical manner, including adopting business practices that prevent or eliminate modern slavery and human trafficking from taking place.

Our supplier code of conduct outlines the guidelines and standards to which we expect our suppliers to adhere, including our stance on modern slavery. This code is presented to each supplier during the onboarding process to ensure their compliance with these standards.

As part of our sourcing process, we require key, critical suppliers and those identified at risk of modern slavery to complete a Responsible Business questionnaire to understand the businesses within our supply chain better, gain visibility of their processes, and identify opportunities for mutual support.

We joined the UN Global Compact (UNGC) in 2020 and in doing so committed to the ten United Nations Global Compact (UNGC) Principles and key themes of human rights, labour, environment and anti-corruption, including principles one ('the protection of internationally proclaimed human rights') and four ('the elimination of all forms of forced and compulsory labour'). We further endorse the aims of the UNGC in our annual published Sustainability Report.

We took part in the UNGC's Business and Human Rights Accelerator in 2024 leading to an action plan focussing on supply chain activity.

We are continuing to embed a consistent approach to ongoing supplier management, incorporating governance processes and templates to ensure that risks are monitored and reduced.

Labour Practices

We are an accredited Living Wage Employer certified by the Living Wage Foundation. The real Living Wage rates for 2024/2025 were announced in October 2024 and implemented from 1 November 2024. We also operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner:

Whistleblowing Policy
Respect At Work Policy
Recruitment Policy
Procurement Policy

3) Assessing & Managing Risk

We have a Modern Slavery Working Group (WG) focused on addressing risks related to modern slavery, ensuring that appropriate measures are in place to assess, manage, and minimize these risks. This WG includes representatives from Procurement, General Counsel, Human Resources and legal teams. The WG feeds into the Human Rights and Business Ethics Steering Group (SG), chaired by General Counsel, guiding the Executive Board.

Due to the nature of our business we assess the risk of modern slavery in our own business to be very low and we manage that risk through the HR measures outlined in the previous section.

We have established an approach for assessing risk for each supplier as they are onboarded, focusing on factors such as geographical location, industry sector, and the nature of the goods or services provided. Suppliers operating in high-risk regions or industries are scrutinized more closely. We have already identified that certain categories of suppliers in our supply chain give rise to higher risk of forced labour, which are subject to additional due diligence including completion of a Responsible Business questionnaire and checks on modern slavery and human trafficking statements.

Additionally, we require our suppliers, both current and prospective, to meet specific standards in areas such as information security risk, employee management, legislative compliance, business continuity, and environmental standards. If we identify a supplier or prospective supplier as being at risk of not meeting these standards (including compliance with the Modern Slavery Act 2015), we collaborate with them to address the risks.

We have established a Contract Signature Policy that outlines the internal governance procedures for approving financial transactions and signing supplier contracts. This policy ensures that appropriate checks and balances are in place, with reviews and authorisations conducted by senior and qualified personnel.

We enforce policies and procedures regarding employment screening (including work eligibility checks) and employment conditions (including our London Living Wage commitments).

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 address through additional due diligence or engagement with the supplier.

4) Due Diligence in relation to Modern Slavery

Our procurement process includes a series of assessments, starting with the supplier risk assessment, sourcing requirements (business case), followed by the request for proposal (RFP), the evaluation assessment and then tender report. the latter documents the RFP process and recommends the supplier based on the assessment results and information obtained during the process. This results in the contract risk assessment, contract approval form and associated signing. These checkpoints ensure that risks are considered at each stage, appropriate information is gathered, and supplier selection decisions are made with an awareness of any associated risks identified including modern slavery.

Our due diligence procedures also aim to provide protection for whistleblowers.

5) Training

Our Head of Procurement and member of the General Counsel Team, supported by a Partner in the business specialist Human Rights, have completed the UNGC's Business and Human Rights Accelerator programme, equipping them with the skills to identify key issues and risks and how to address them.

We encourage our suppliers to adopt practices that align with our values and responsible business objectives, and we regularly collaborate with others to enhance our positive impact. Whenever possible, we invite our onsite suppliers to participate in our campaigns.

All people are required to complete e-learning modules to raise their awareness of modern slavery, risk areas, and common signs.

Specifically, we require them to complete training and ongoing refresher courses on slavery and human trafficking. Training covers:

How to identify 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 relevant parties within the business
What external help is available
What steps we should take if suppliers in our supply chain do not implement anti-slavery policies in high-risk scenarios, including their removal from our supply chain

6) Monitoring & Evaluation

We will continue to develop our approach to combating modern slavery and human trafficking, assess and manage any risks on an on-going basis and develop key performance indicators to measure the effectiveness.

We continue to review our procurement process to ensure consistency in our approach to engaging with suppliers and encourage greater transparency in their ways of working. We are constantly updating and improving our processes as part of our improvement programme.

We use the following activities to inform improvement and report progress on environmental, social and governance (ESG) themes including those relating to modern slavery:

Annual Sustainability Report
UNGC Communication on Progress (CoP)
Risk-focussed internal audit and assurance External audit (carried out by EcoVadis) reflects modern slavery themes and other themes - a scorecard is available on request

Business wide governance processes, disclosures and human rights activity are further defined on our website here. Governance | Gowling WLG

This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and constitutes Gowling WLG (UK) LLP's modern slavery and human trafficking statement for the financial year commencing 1 May 2024 and ending 30 April 2025.

The Gowling WLG (UK) LLP Executive Board approved this statement on 09th July 2025.

Signature:

David Fennell signature