米odern Slavery Statement 2017

Statement pursuant to section 54 of the Modern Slavery Act 2015

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.

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

政策

We have aGlobal Corporate Responsibility Policywhich, 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. TheGlobal Procurement Policy and Guidelinesaim 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.

TheGlobal Contracts Protocolaims 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

As regards existing suppliers,following on from our 2016 supplier review which assessed the risks of modern slavery or trafficking being present in our supply chain in each country in which we operate, we noted in our 2016 statement that the main area of risk identified was in the sourcing of marketing and promotional materials which have historically been sourced from multiple vendors. We have now appointed a single vendor for these items in respect of which appropriate due diligence in accordance with our policies referred to above was conducted.

As part of our regular scrutiny of key suppliers, we have in the past year completed an audit of our catering supplier to establish that all ingredients and produce utilised by it were sourced in an ethical manner. Our catering supplier was able to provide evidence of the audits it carried out on its own supply chain and, as a result, Ashurst is satisfied that our catering supplier is aware of its obligations with respect to its supply chain and confident that enforced labour is not present in the supply chain, in the UK or abroad.

We are in the process of performing an audit of our IT hardware suppliers and will report on the outcomes of that in our 2018 statement.

As regards 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.

Training of staff involved in procurement

We have recently 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.

Ben Tidswell, Designated Member on behalf of Ashurst LLP and Director on behalf of Ashurst Business Services Limited
26 October 2017