Anti-slavery and human trafficking statement

1. Opening statement from Senior Management

Corporate responsibility is a core value of Paul Hastings (Europe) LLP (“the Firm”)[1] and we are committed to conducting our business ethically and with integrity. We recognise that modern slavery, which includes slavery, servitude, forced and compulsory labour, and human trafficking, is a serious global issue affecting millions of people, the impact of which can be devastating for the victims.

We are committed to preventing all acts of modern slavery from occurring within our business and supply chain and we expect the same high standards of our suppliers.

The Firm’s Business and Human Rights practice also works with clients to help them avoid involvement in modern slavery and human trafficking. The team represents the world’s largest and most sophisticated companies on complex human rights matters, multifaceted international disputes, and growing compliance obligations. Our work spans all aspects of business and human rights, including disputes and investigations; government hearings and enforcement proceedings; assessment and due diligence; governance systems; grievance mechanisms; disclosures and ongoing advice. We have developed, implemented, overseen and monitored global standalone human rights programs and assisted in integrating human rights into existing anti-corruption and internal regulatory compliance programs.

We also address human rights issues in our pro bono work, with a particular emphasis on the issue of modern slavery and human trafficking. We have taken a three-pronged approach to combatting modern slavery by: 1) engaging in global research and writing projects alongside international organisations and governmental bodies in order to advance human rights protections; 2) supporting organisations alongside our business clients that investigate and advocate against human rights abuses; and 3) providing direct legal support to survivors of human rights violations, including human trafficking victims, as well as assisting them in rebuilding their lives.

This statement is made on behalf of the London office of the Firm pursuant to section 54(1) of the Modern Slavery Act 2015[2] (“the Act”). The statement outlines the steps we have taken during the financial year ended 31 January 2026 to prevent modern slavery and human trafficking within our business and across our supply chains. We continue to review and strengthen our policies, practices, and partnerships to uphold the rights and dignity of all individuals connected to our firm.

2. Structure of the Organisation

The Firm, together with its associated partnership, Paul Hastings LLP, provides legal services across a wide range of disciplines and sectors, with over 1,000 lawyers servicing clients' global needs from 24 locations around the world including in North and South America, Europe, Asia and the Middle East.  With widely recognized elite teams across 17 core practices, Paul Hastings is a premier law firm with a culture of excellence focused on providing intellectual capital and superior execution globally to the world’s leading investment banks, asset managers and corporations. To find out more about the nature of our business, please visit our website: http://www.paulhastings.com.

Within this international structure, the Firm operates through a separated legal entity which is responsible for the European operations covered by this statement. The Firm operates as a limited liability partnership in England and Wales under registered number OC306535. The registered office is London, with branches in Brussels, Frankfurt and Paris. The Firm is authorised and regulated by the Solicitors Regulation Authority (“SRA”) (SRA ID 398385). The members of the Firm are solicitors or registered foreign lawyers authorised to practice in England & Wales.  There are approximately 300 lawyers and support staff in the London Office.

Our operations are primarily office-based and professional in nature, and the vast majority of our workforce comprises qualified legal and business services professionals employed directly by the Firm. As a provider of legal services, we recognise that the overall risk of modern slavery within our own operations and immediate supply chain is relatively low.  Our supply chain is not expansive, nor is it characterised by complex subcontracting structures or opaque sourcing arrangements. Nevertheless, we remain alert to the potential for exploitation in any supply chain, particularly in areas such as facilities management, IT services, recruitment, and professional services procured from third parties.

3. Governance

In accordance with the SRA’s standards and regulations, we have appointed a Compliance Officer for Legal Practice ("COLP"). The COLP is responsible for ensuring that the Firm has policies and procedures in place that are designed to ensure compliance with all applicable laws and regulations, including the Act.

The Risk and Compliance department supports the COLP by monitoring legal and regulatory developments, reviewing and updating the Firm's policies and procedures, and providing guidance to the business on modern slavery and related compliance matters.

The Vendor Management team acts as the first point of contact for supplier onboarding and ongoing supplier management. Working closely with the Risk and Compliance Department, the Vendor Management Team supports the Firm's supplier due diligence process and helps ensure that suppliers understand and meet the Firm's ethical expectations, including those relating to modern slavery. The team also ensures all relevant contracts are reviewed by Associate General Counsel to ensure location specific requirements are included in supplier contracts.

4. Policies

We are committed to ensuring that there is no modern slavery in any part of our business and supply chain. Our commitment reflects our desire to be a responsible business which operates ethically and with integrity. We maintain a suite of policies and procedures that reflect our commitment to acting ethically, responsibly and in compliance with all applicable laws, including the prohibition of modern slavery and human trafficking. These policies help us embed high standards of conduct throughout our operations and in our dealings with suppliers and third-party service providers. Our approach is to ensure that our suppliers are aware of our policies and adhere to the same high standards as the Firm.

Key policies relevant to the identification and prevention of modern slavery include:

1. Modern Slavery Statement: this outlines our zero-tolerance approach to modern slavery and sets out our expectations of employees and suppliers;
2. Vendor Code of Conduct: this communicates our ethical standards and the behaviours we expect from third parties who work with or on behalf of the Firm, including specific prohibitions on the use of forced, bonded or involuntary labour;
3. Specific Vendor Terms and Conditions: we have a Firm specific addendum which we request be added to all contractual terms with external suppliers.  The addendum governs the Vendor’s compliance with the Firm’s modern slavery requirements throughout the contractual relationship, including obligations to notify the Firm promptly of any actual or suspected breach, and the Firm’s right to terminate the agreement where these requirements are breached. This has replaced our Vendor Code of Conduct.
4. Procurement Policy: this integrates ethical sourcing considerations into our supplier onboarding and contract renewal processes.
5. Whistleblowing Policy: this provides a confidential channel for employees and third parties to report concerns relating to unethical conduct, including suspected modern slavery;
6. Our Employee Handbook: this reinforces our commitment to fairness, dignity, and respect in the workplace and beyond.

These policies are reviewed periodically and updated as necessary to reflect changes in legal requirements, industry expectations, and our own risk environment.

5. Risk Assessment and Due Diligence

We seek to work with suppliers that share our values. We expect our suppliers to operate fair and ethical workplaces and do not tolerate any form of modern slavery within our supply chains.

Supply Chains

The Firm engages suppliers for the provision of a range of goods and services in the areas of talent management, technology, office cleaning and facilities services, and other professional services (from barristers to other advisers). These are obtained to enable our lawyers to service our clients, and to support the efficient running of our Firm.

Due Diligence

The Firm evaluates the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain by reviewing and evaluating suppliers using reputable third party providers and databases. As a professional services organisation that does not operate in high-risk sectors or locations, we consider the risk of modern slavery existing within our business to be low, although we are conscious that limited parts of our supply chain e.g. cleaning services, may present a higher risk.

The legal sector, while generally considered low risk in terms of exposure to modern slavery, still has a responsibility to implement robust processes to identify, assess, and manage potential risks within its operations and supply chains. Our due diligence approach is risk-based and proportionate to the nature of our business. It is designed to ensure that we only work with suppliers or third-party partners whose values and standards align with our own. Key elements of our due diligence process include:

1. Supplier onboarding and screening: new suppliers undergo a risk assessment that includes a due diligence process, and conflicts checks that track reputational concerns; and
2. Ongoing supplier monitoring: we maintain regular oversight of key suppliers and conduct periodic reviews to ensure continued compliance with our ethical expectations.

Our procedures are designed to:

• establish and assess areas of potential risk in our business and supply chains;
• reduce the risk of slavery and human trafficking occurring in our business and supply chains; and
• provide adequate protection for whistleblowers.

6. Training

We recognise that awareness and understanding are essential to preventing modern slavery and ensuring compliance with relevant legislation, including the Act, as such, we are committed to providing appropriate training and guidance to employees and relevant third parties. We invest in educating our staff to recognise the risks of modern slavery in our business and supply chains. Our policies and procedures are made available to all staff via the Firm's portal, and the Employee Handbook includes our Code of Conduct, which sets out the ethical standards we expect everyone working for the firm to meet.

Specific training and guidance will continue to be provided to employees in the London Office, to assess the human rights and labour performance of suppliers.

We continue to review the effectiveness of our training programme, and we will expand and adapt it as needed to respond to changes in risk exposure, regulatory developments and feedback from employees and suppliers.

7. Steps going Forward

We acknowledge that the fight against modern slavery and human trafficking is an ongoing challenge, requiring continuous vigilance and improvement. We commit to undertaking an annual review of the effectiveness of our procedures to ensure that slavery, forced labour or human trafficking are not taking place in our business and supply chain. In the coming financial year, we intend to build on our existing efforts by doing the following:

1. Improve supplier mapping and risk assessment: continue improving our supplier risk assessment methodology to reflect changes in geographic, economic and social conditions and to consider relevant factors including the supplier’s location, industry, sector, nature of services and use of subcontractors.
2. Further embed modern slavery awareness across the Firm: developing and strengthening the internal reporting channels and support for the departments with greater exposure to supplier risks.
3. Improve documentation and reporting: strengthen engagement and dialogue with suppliers. This will help support the identification, escalation and management of modern slavery risks and ensure that our approach remains aligned with relevant government guidance and industry best practice.
4. Strengthen supplier engagement and controls: continue reviewing and updating  policies and documentation including where appropriate incorporating relevant real-life case studies and lessons learned from within the Firm, our suppliers, and industry peers.