This statement is made pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 on behalf of Dentons UK and Middle East LLP (the Firm) and all group companies including but not limited to Dentons UK and Middle East Legal Services (the Group, or 'we'). The Firm is the controlling party within the Group. The statement sets out the steps the Group has taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business. The Firm's financial year end is 30 April and this constitutes our slavery and human trafficking statement for the 2023/2024 financial year.

CEO's statement

We recognise the suffering which modern slavery and human trafficking causes. In an increasingly global marketplace, we recognise that all businesses have a responsibility to understand whether modern slavery and human trafficking is taking place within their supply chains and this is a responsibility we take seriously.

Our organisation

The Firm is an English limited liability partnership with registration number OC322045. We have four offices in the UK, located in London, Milton Keynes, Edinburgh and Glasgow. We provide a full range of legal services to corporate clients from many sectors, including telecommunications, energy, real estate, financial services and retail.

Dentons UK and Middle East Legal Services is an English unlimited company, registration number 2746217. The company is based in London although operates throughout all the Firm's offices in the UK. The principal activity of the company is to provide staff services to the Firm.

We are a part of Dentons, a global legal practice providing client services worldwide through its member firms and affiliates.

We had an annual turnover in 2023/2024 in excess of £36 million.

Our supply chains include leases for the properties we occupy, catering services, some outsourced business process services, recruitment and employment agencies and the purchase of goods including office furniture and supplies and IT software and equipment.

As a law firm, we always work to the highest professional standards and comply with all laws, regulations and rules relevant to our business. Corporate social responsibility is an intrinsic part of our culture and we aim to make a lasting and positive impact on the communities in which we live and work. We expect the same from our suppliers and business partners.

Our policies on slavery and human trafficking

The Group is committed to ensuring we are not supplied by anyone who engages in human trafficking and modern slavery. Please see our Anti-Slavery Policy.

The Anti-Slavery Policy has been approved by our management, and ultimately the Chief Executive Officer, as head of our region and the named Group, is responsible for this Policy. A team led by our General Counsel, working closely with our Operations, Procurement, Information Security, and Compliance functions implements the Policy.

We also have a Whistleblowing Policy, which is published on our intranet site. If employees have concerns about any wrongdoing or breaches of law, they can raise these concerns in confidence without fear of disciplinary action.

What we are doing

Our working practices respect and uphold human rights for our partners, employees, and contractors.

We take the following steps to identify risks of modern slavery and human trafficking within our business and our supply chain:

• We assess risk related to human trafficking and forced labour associated with our supply base. We assess suppliers against the following risk areas: reputational, financial, information security, data privacy, legal compliance, business continuity and procurement. We are implementing an automated assessment which will be introduced for all suppliers, this will include a statement to confirm that we have the right to audit any suppliers for any concerns or red flags of modern slavery.
• We carry out due diligence on all relevant and appropriate suppliers by asking for information on their policies on fair sourcing of goods and services, and employment practices. In respect of certain suppliers, we seek the right to request and receive copies of their policies.
• We have a code of ethical business practices, which we share with all relevant and appropriate suppliers and which we expect our key suppliers to adhere to. The code sets out the standards we expect our suppliers to uphold at all times relating to various matters including anti-bribery and corruption, human trafficking, slavery, and ethical behaviour.
• We have in place a programme of training on modern slavery and human trafficking that is mandatory for all staff as part of our induction training. Training requirements on modern slavery will be kept under review for those staff members working in human resources and procurement.
• We have a programme of refresher training for all staff within our region to educate and remind them of their obligations under the Modern Slavery Act 2015, this was delivered during 2023 and we plan to do so again within the next 12 to 24 months. The refresher training will act as an on-going reminder of the importance of our obligations in tackling modern slavery.
• We will seek to impose contractual terms on relevant and appropriate suppliers asking them to warrant that they and their suppliers are in full compliance with our Anti-Slavery Policy. We will seek to audit our suppliers where there is deemed to be considerable risk or we have concerns of non-compliance to ensure that this is the case. The right to audit will now be included in our code of ethical business practices.
• We implement a vendor management system, which stores all vendor documentation. Included in the forms we ask vendors to complete, vendors must confirm if they have a Code of Conduct for their own supply chain prohibiting child labour and modern slavery and ask whether they have a right to audit their suppliers under this code. We also ask for details and evidence of further measures they have implemented to eliminate modern slavery in their supply chain.

Approval

This statement has been approved for and on behalf of the members of Dentons UK and Middle East LLP and by the Board of Directors of Dentons UK and Middle East Legal Services.

Paul Jarvis 
UKIME Chief Executive Officer of Dentons UK and Middle East LLP
Authorised Representative of Dentons UK and Middle East Legal Services