Modern Slavery
Statement 2024
Sustainability is our businessCEO Foreword

We are committed to proactively andsystematically addressing the risk ofmodern slavery in our own operations andacross our value chain, in recognition of ourindividual and collective responsibility torespect and promote human rights in society,consistent with the UN Declaration of Human
Rights, UN Guiding Principles on Businessand Human Rights, International Labor
Organization Principles and Fundamental
Rights at Work and UN Sustainable
Development Goals.
Tom Reichert, ERM Group CEO
MODERN SLAVERY STATEMENT 20242

This document comprises the Modern Slavery Statement 2024 for The ERM
International Group and all of its global subsidiaries including those encompassing
operations in Canada and Australia. The complete list of ERM subsidiaries, which
includes ERM Worldwide Group Limited, Environmental Resources Management
Limited and ERM-Europe Limited, as of 31 March 2024, can be found on erm.com.

Recognizing the diverse forms of modern slavery

This Statement is published pursuant to section 54(i) of the UK Modern Slavery Act
2015 and section 14 of the Australian Modern Slavery Act 2018 (Joint Modern Slavery
Statements). ERM does not currently meet the definition of a reporting entity
under the terms of section 11 of the Fighting Against Forced Labor and Child Labor
in Supply Chain (Canadian Modern Slavery Act) 2023 but is voluntarily reporting
consistent with the provisions of the Act.

ERM recognizes that it is our responsibility to respect the human rights of ouremployees and stakeholders and to support the eradication of modern slavery in all its
forms. We support and align our work to the UN SDG Goal 8.7, which seeks to eradicate
modern slavery amongst children by 2025 and universally by 2030**.

This Statement describes the specific action undertaken in the fiscal year ending
31 March 2024 (FY24) and notes plans for the next fiscal year (FY25). This Statement
should be read in conjunction with our previous Modern Slavery Statements, our
Human Rights, Modern Slavery and Child Labor Policy and wider corporate policies
available to view at erm.com.

Forms of modern slavery

It is estimated that over 50 million people* are subjected to modern slavery, and recent
years have seen a sustained increase in those affected. Modern slavery exists across allparts of the world and in many forms, not all of which are easy to recognize but arenonetheless important to mitigate against.

Trafficking of people for sexual andeconomic exploitation includingchildrenForced labor

Bonded labor including debt bondage

Child labor

Domestic servitude

Forced marriage

Signed on behalf of the Board of Directors and Executive Committee
Tom Reichert
Group CEOThe ERM International Group Ltd
Company registration no.: 13391605*Global Estimates of Modern Slavery, Forced Labor and Forced Marriage, Report by International Labor Organization (ILO),
Walk Free, and International Organization for Migration (IOM) 2022**Goal 8 | Department of Economic and Social Affairs (un.org)

MODERN SLAVERY STATEMENT 2024

3

Our structure, activities andsupply chain​

Value chain approach​
ERM is the world’s largest specialist sustainability
consultancy. We operate as a services company, delivering
strategic advice and technical expertise to clients acrossthe globe.
We adopt a value chain approach to management ofmodern slavery risk, recognizing the potential for
modern slavery risk in our direct operations and thatof our supply chain but also the opportunities to work
collaboratively with our clients and organizations suchas the UN Global Compact to address modern slavery in
all its forms.

Direct operations

Supply chain

GOVERNANCEDISCLOSURE

POLICIESAND
PROCESSESPERFORMANCE

Upstream our value chain includes employees, partners
and investors who are shareholders in the business,
our offices and the materials required to support them,and the services provided by the diverse suppliers andcontractors who comprise our supply chain. Downstream,
are our clients, the communities they operate in andtheir own supply chains, alongside partner organizations,
global society and environment. Across our value chain,
we seek to work with organizations who share our
purpose and values.

MODERN SLAVERY STATEMENT 2024

Clients

Partnerships

Our structure​
We operate as a services company, delivering strategic
advice and technical expertise to clients across theglobe. Our organizational structure is built aroundour Partnership model, where ERM Partners are theshareholding managers and leaders of the firm. ​The ERM Board of Directors is responsible for the
direction and oversight of The ERM International Group
Limited (as parent company of the ERM Group) on behalfof its shareholders. ​This statement encompasses the Group and all its
subsidiaries globally. All subsidiary companies either
carry out the principal activities of the Group, namely theprovision of environmental, health, safety, risk, social,and sustainability consulting services, or are holding
companies. ​ERM has more than 140 offices in over 40 countries andterritories and employs 8,000 people globally.

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Our activities
We operate primarily from our offices of which we have 149, located in over 40 countries
and territories. We, however, also work from client offices and assets and also conduct
in-field or survey activity to support out services to client.

Our operational presence in respect of the UK, Canada and Australia is highlighted
on the right but consistent with our approach to managing modern slavery risks,
this statement addresses the breadth of our operations globally.

Services and sectors
Our diverse global team of experts works with the world’s leading organizations to help
them set clear sustainability targets, measure progress and operationalize strategy
through deep implementation and business transformation. We offer services tosupport clients across their operational needs, for further information please refer to
ERM's services.
Our supply chain
The nature of ERM’s business as a services company means that we subcontract
services to support the delivery of our work. Our supply chain is diverse, spanning thebreadth of our global offices and countries within which we deliver our services. Thisis an area where the potential for modern slavery exists beyond our direct operational
control but we have the potential to influence. Our focus in FY24 and continuing in
FY25 is, therefore, on identifying the opportunities to further strengthen our visibility,
management and remediation of modern slavery risk in our supply chain. More detailed
information is available in the ERM Sustainable Supply Chain Strategy.

United Kingdom

CanadaAustralia

9

14

10

338

1,195

481

Offices

Employees

Offices

Employees

Offices

Employees

A full list of The ERM International Group Limited’s subsidiaries can be accessed at: erm.com

MODERN SLAVERY STATEMENT 2024

5

Our assessment of material risks of modern slavery
across our value chain
We adopt a value chain approach to the assessment of material risks of modern slavery.
We will continue to evolve our assessment of key areas where the potential for modern
slavery exists, including through targeted human rights due diligence assessments andthe effectiveness of our approach to managing these risks.
People and offices
Our employees and those with whom they work to deliver our client services, are at riskof modern slavery. Risk of modern slavery also exists within our own operations, withrespect to the offices we operate from. This risk emanates from the management firms
and owners of the buildings within which we lease offices and from those whom thesecompanies employ in office service roles such as facilities management and security
side. Outside of our offices, employees may conduct in-field or survey activities inlocations across the world. The potential exists for our employees and contractors toencounter persons who may be at risk of modern slavery or activities which suggestthat modern slavery is occurring.
Services
Whilst we deliver specialist advice to clients on human rights and modern slavery
risk management, we also deliver thousands of wider projects to clients and needto proactively identify where the risk of modern slavery may arise in respect of thedelivery of these. During the delivery of those projects, it is also possible for our
employees to consider some of the operational practices or employees whom theyencounter, as being at risk of modern slavery. This may be a particular risk whenworking in client offices or wider assets, including conducting services such as audits
on behalf of clients.

MODERN SLAVERY STATEMENT 2024

Supply chain
The potential exists for modern slavery in the companies whom we contract to supportdelivery of our client work and with those whom our contractors may sub-contract
to themselves i.e. their own supply chain. This risk may be heightened in certain
geographies or in the delivery of certain services.
Partnerships and collaborations
The risk of modern slavery exists within the organizations whom we partner with,commercially, strategically and through the work of the ERM Foundation.

The remainder of this statement is structured as follows to provide the reader withinformation on our management of modern slavery risk:

1.

Governance, policies and processes to proactively manage modern
slavery risk

2.

Our people and offices: managing modern slavery risk in relation to ouroffices, our people and the delivery of our work3.

Our services: managing modern slavery risk in our service delivery andsupporting our clients to manage and report on modern slavery risk intheir own operations

4.

Our supply chain: managing modern slavery risk arising from our useof suppliers across our global operations

5.

Our partnerships: opportunities to collaboratively raise awarenessaround modern slavery

6.
7.

Performance, grievance mechanisms and remedies
Reporting6

1. GovernanceOur structure
The Board of Directors and Executive Committee are
ERM’s highest governing bodies. The Board is the highest
authority and ultimately responsible for the strategic
direction, governance, and oversight of The ERM
International Group Limited (as parent company of the
ERM “Group”) on behalf of its stakeholders. The ESG Risk
and Sustainability Steering Group serves as an advisorygroup to the ERM Board. It works in conjunction with theBoard to oversee the identification and mitigation of risks
relating to ESG and reputation, including human rights
and modern slavery risks.

Board

ERM ESG Risk
& Sustainability
Steering Group

Executive
Committee

ExComWorkingGroup

SME
Working
Group

MODERN SLAVERY STATEMENT 2024

The Executive Committee (ExCom) which feeds into
Board, has accountability for managing the sustainability
impacts of the organization, including human rights andmodern slavery risks throughout our operations. The
ExCom meets seven times a year to discuss operational
performance and to ensure key strategic responses tohuman rights related risk and opportunity are being
implemented effectively. The ExCom is supported by the
ExCom Sustainability Working Group, which advises on
all aspects of operationalizing sustainability across ourvalue chain, including our management of modern
slavery risks through strategy, programmatic priorities,
target setting and resourcing. The Working Group reports
into ExCom on all aspects of operational sustainability
strategy, performance and reporting and is supported
by our subject-matter experts across all aspects ofsustainability, including human rights and modern
slavery management.
Supporting ExCom are our operational and businesssenior leadership, who are responsible for our
performance and adherence to organizational policies
and programs, including our approach to Human Rights
and management of modern slavery risks across the value
chain.
Leadership and accountability
The promotion of human rights and management ofmodern slavery risks is fundamental to ERM’s purpose
and is led from the top of our organization, our CEO.
ERM’s Global Head of Sustainability and Risk (GHSR)
has overall accountability for our strategic approach
to risk, which includes those risks associated with

Modern Slavery. Our GHSR is a member of ERM’s Board
and ExCom, co-chairs and convenes the ESG Risk andSustainability Steering Committee to the Board andchairs the ExCom Sustainability Working Group. Our
GHSR works in conjunction with our Group GeneralCounsel and Chief Compliance Officer, to oversee
compliance with the UK Modern Slavery Act (2015),
and the Australian Modern Slavery Act (2018) and theCanadian Modern Slavery Act (2023). Their work is
supported by our senior leaders, including our Global
Director for Sustainability, Head of Risk and Head of
Sustainability, and supported by wider functional
leads across the business, including People, Clients andServices and Procurement, amongst others.
Across our global operations, our partners assume a key
leadership role in implementing our global approach. In
accordance with the UN Declaration of Human Rights,
ERM also believes it is the individual and collective
responsibility of all our employees to respect andpromote human rights. To this end, all employees are
expected to demonstrate leadership in our managementof modern slavery risk. Our employees receive training
and are empowered to report any concerns they may
have through our Legal and Compliance, project
management hierarchy or through our helpline,
further details of which are subsequently set out inthis Statement. We will continue to work on enhancing
awareness and understanding of modern slavery risks
across the business and to provide catered guidance tospecific sections of our employee base, including ouroffice managers, facilities, procurement and project
management personnel.

7Policies
As part of our ongoing support for the promotion of international human rights,
we have continued to use our participation in the UNGC and other international
developments as the basis to improve our policies, procedures, and approach tobusiness. All policies referred to in this section can be viewed on erm.com.
We express our commitment to conducting business with uncompromising honesty andintegrity though our business values, professional standards, employee training and ourinternal systems and practices.
Human rights is embedded in our operational governance: our Business Code of
Conduct and Ethics is available in 18 languages and all employees must act inaccordance with this. Our Code sets out clear and unequivocal requirements onadherence to the highest ethical standards.
As reported in FY23 our Human Rights, Modern Slavery and Child Labor Policy was
updated to further align with emerging best practice. Our policy prohibits the useof child or forced labor in our own operations and that of our supply chain and any
involvement by ERM with organizations that support prohibited labor practices orhuman trafficking. This policy works in conjunction with ERM’s purpose and beliefs
and Code of Business Conduct and Ethics.
ERM’s Sustainability Policy articulates our commitments to sustainability, including
social and economic development of communities, which can meaningfully contributeto the alleviation of modern slavery. The policy applies globally to all ERM entities andall ERM employees. Our policy framework and corporate governance disclosures are
mapped in ERM’s Sustainability Report, the Global Reporting Initiative (GRI) Index, andin ERM’s Communication of Progress to the UNGC.
Specific to our supply chain:
Our Supplier Code of Conduct outlines our commitment to working with suppliers
who have embedded sustainability, diversity, and ethical practices within their own
organization and supply chain. It contains specific reference to labor and humanrights and articulates that suppliers we work with must have public commitments andprocesses in place to prohibit slavery in all its forms across the supply chain,

MODERN SLAVERY STATEMENT 2024

and prohibit unlawful discrimination and harassment of workers. ERM contractuallybinds our suppliers to our Supplier Code of Conduct.
Our Partners use our purpose, values, policies, and internal governance arrangements
to support out working culture based on sustainability principles, which includes fairlabor and treatment to all.
Risk management
Our approach to identifying salient human rights risks and impacts enables ERM toassess risks at the local, business unit, regional, and companywide levels. We consider
risks associated across our operations and value chain, including our work with clients,
subcontractors, suppliers, and the communities in which we operate.
We recognize the importance of reflecting the different priorities and challenges, which
regions or geographies face, but also the common driver of protecting and promoting
human rights which unites us and our stakeholders globally. A further detailed
assessment of geo-political specific human rights risk, will be undertaken in FY25.
An annual assessment of our human rights-related risks, opportunities and impacts
is undertaken by our Group Sustainability and Risk function, working in conjunction
with other functions and operational units. This assessment also informs our double
materiality assessment process and material risks are fed into our enterprise risk
management register. The register is actively reviewed and updated throughout theyear on the basis of additional emergent risks and is used to inform our strategic andoperational planning, including our Human Rights operational program and strategy.
We have introduced a risk-based project screening requirement to help us identify
more systemically the potential adverse human rights impacts of our project work withclients, enabling us to take the appropriate measures to avoid causing, contributing or
being linked to such impacts.​
For further information, see the ERM Sustainability Report and ERM Human Rights
Strategy.

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2. People and offices
ERM’s primary asset is our people, just over 8,000 of whom
work in our operations, with our clients and suppliers, andengage with our wider stakeholders. Below are some of theways in which we seek to manage risk of modern slavery
within the management of our people.
HR management
ERM has an extensive People Function operational across our global operations andaddressing the breadth of our people function, from recruitment and retention toemployee management, health and wellbeing, and professional career development.
As part of introductory mandatory training, ERM employees are required to review
our Global Code of Business Conduct and Ethics, Sustainability Principles, and Modern
Slavery training within the first two months of joining the firm. Compliance is actively
reviewed by our Group Learning and Development, Legal and Sustainability teams.
Training
The delivery of our human rights and modern slavery risk management is theindividual and collective responsibility of all employees at ERM. To reflect this, in FY24,
we have expanded our mandatory human rights and modern slavery training module
to encompass all employees, regardless of position or seniority. All employees must also
complete refresher training to ensure their knowledge and awareness remains up todate.

Our offices
We have offices in over 40 countries but our work has an even broader geographicalreach. Our management of modern slavery is, therefore, global in its approach whilst
recognizing that the profile of modern slavery risk can vary on a country or regional
basis, subject to a range of factors including geo-political and socio-economic context.
Our offices are run by our Operations and Facilities Teams, under the leadership ofour business unit senior leadership. All offices operations must adhere to our global
management policies and protocols, including those pertaining to Human Rights andModern Slavery. During FY25, we will be further developing guidelines to equip ouroffice management staff with further understanding of how modern slavery risks may
arise in relation to this specific aspect of our operations. We will also commence further
due diligence assessments of those companies with whom we lease our offices, as part ofour supply chain management strategy.
Conducting our work with clients and in-field
As a leading provider of sustainability consultancy services, including environmental,
health, safety, risk, social and human rights consulting amongst others, we have abroad sectoral coverage, encompassing clients across industry sectors. We provide
both office-based services and on-site work all over the world. Our work takes us to adiverse range of locations including manufacturing plants, construction sites, minesites, offshore and onshore rigs, factories, agricultural and rural areas, amongst manyothers. We are alert to the potential for our employees to observe modern slavery whilst‘in-field’, on client sites and/or sites owned and managed by third parties. Our training
to employees emphasises the importance of remaining vigilant to this potential andreporting any suspected incidence of modern slavery through the appropriate channels,
as outlined in our Grievance Mechanism section of this Statement.

Dialogue and discussion
We encourage an open dialogue about modern slavery, both within our business
and with our wider stakeholders. Through this we believe that our collective
understanding of this challenging topic can be enhanced and we both contributeto but also learn from the shared discussion.
MODERN SLAVERY STATEMENT 2024

9

3. Our services
Due diligence of clients and projects
ERM is committed to identifying and addressing impacts to human rights andmodern slavery throughout our value chain, driving better performance across all
our operations. We undertake a range of due diligence to assess potential risks aroundhuman rights and modern slavery arising from the delivery of our work and have
remedial measures in place to address behaviors and practices which we consider
inconsistent with our Human Rights Policy. We encourage all employees, clients,
suppliers, and the wider general public to raise ethical and legal concerns about theoperations of ERM or its supply chain, including potential human rights concerns. We
treat all concerns raised seriously and have a zero-tolerance approach for retaliation.
Our CRM tool includes pre-screening of potential clients to identify potential issues
with the sustainability performance of prospective clients, this including an ESG risk
assessment. All opportunities must be recorded on the system which includes screening
questions on the nature of the work to be undertaken. If the screening identifies thepotential for such impacts, the opportunity must then be taken through the ERM
Sustainably Transparent Assessment of Risk and Reward (STARR) process.
The STARR process provides a framework for further due diligence of those projects
identified as potentially having a higher sustainability risk, including potential impacts
to nature. The opportunity lead must provide further information which is thenconsidered by our Global Head of Risk and further information or mitigation measures
may be required, if appropriate.
Impact of our services
As a leading provider of sustainability consultancy services, including environmental,
health, safety, risk, social and human rights consulting amongst others, we havea broad sectoral coverage, encompassing clients across industry sectors. Our mostmaterial risk and opportunities exist with respect to the services we provide to clients,
how these are conducted and the impact which they can generate with respect tomanagement of modern slavery risks.

MODERN SLAVERY STATEMENT 2024

We provide specialist expertise to clients supporting them to manage the social impactof their own operations, including management of modern slavery risk. We also
undertake work for clients across a much broader spectrum of services and are working
to identify and manage the risk of modern slavery within these, particularly in services
such as low carbon energy transition and permitting where risks may emerge in respectof where and how client projects may be located, constructed and operated.
Conducting our work with clients and in-field
We provide both office-based services and on-site work all over the world. Our worktakes us to a diverse range of locations including manufacturing plants, construction
sites, mine sites, offshore and onshore rigs, factories, agricultural and rural areas,amongst many others. We are alert to the potential for our employees to observe
modern slavery whilst ‘in-field’, on client sites and/or sites owned and managed bythird parties. Our training to employees emphasises the importance of remaining
vigilant to this potential and reporting any suspected incidence of modern slavery
through the appropriate channels, as outline din our Grievance Mechanism section ofthis Statement.
Our human rights capabilities
For over 50 years, ERM has helped clients to understand human rights, prevent orremediate negative impacts, and go further to operate in a manner that respects
and advances human rights. We combine an intimate understanding of emerging
international and national requirements with practical on the ground experience tosupport clients in understanding and fulfilling their human rights responsibilities.
This helps protect access to capital, develop and maintain a social license to operate,and ensure regulatory compliance. Our multidisciplinary teams are at the forefrontof human rights and environmental regulatory developments.
We advise clients on a range of issues relating to modern slavery, including
due diligence; policy and strategy development; training; gap, risk, and impact
assessments in operations and supply chains; and disclosures. More detailed
information can be found in our Human Rights Strategy.

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4. Supply chain
The nature of ERM’s business as a services company means that we subcontract services
to support the delivery of our work. This is an area where the potential for modern
slavery exists beyond our direct operational control. Our focus in FY24 and continuing
in FY25 is, therefore, on identifying the opportunities to further strengthen our
visibility, management and remediation of modern slavery risk in our supply chain.
To this end we have strengthened our requirements from all suppliers in respect notjust of adherence to our policies and procedures on human rights and sustainability
more broadly, but we have also instituted new requirements for suppliers to document
their own policies and management.
New procurement
In FY24, we further strengthened our requirements for data on prospective suppliers’
approaches and management of human rights, setting out new specifications in one of
our top spend procurement exercises. This will be further rolled out to wider top tiersupplier spend as new procurement exercises are undertaken.
We have developed specific global requirements for suppliers and subcontractors as partof our supply chain process, with explicit requirements in relation to modern slavery
concerns. This is part of our wider human rights due diligence process.
ERM works with suppliers and subcontractors that demonstrate the following
attributes:• Incorporate safe practices in all commercial decisions;• Exhibit a high level of integrity at all times and in all dealings;• Commit to enhancing human rights and wider sustainability performance;• Demonstrate outstanding quality of work; and• Provide cost savings innovation.

MODERN SLAVERY STATEMENT 2024

Screening of eligible subcontractors
ERM’s process for engaging subcontractors includes the use of a third-party supplychain risk management solution to identify potential or known risks. We combine
this with our Active Leadership Audit Program and subcontractor qualificationassessments to collate and evaluate data on our use of subcontractors to ensure we are
adequately managing and mitigating risk. We review our supplier’s hiring practices,from asking how they recruit employees to requesting records that verify they follow
anti-trafficking efforts. This can include thorough background checks and efforts toconfirm submitted documents where an elevated risk is assessed to exist. A high degreeof due diligence is conducted when engaging labor brokers, especially in high-risk
jurisdictions. We will continue to focus on this during FY25.
We require all subcontractors and third-party suppliers to act in accordance with
our Supplier Code of Business Conduct and Ethics (“Supplier Code”), which includes
specific clauses around human rights and modern slavery, and our broader Human
Rights Policy. Our standard contractual Terms and Conditions bind suppliers to our
Supplier Code and therefore provide explicit expectations and requirements in respect
to addressing human rights, including modern slavery. The Supplier Code consolidates
updates on key international terms such as anti-bribery and corruption, human rights(including prohibitions for all forms of modern slavery) and our health and safetycontractual requirements. Our standard form subcontractor agreements and supplierrelationship management system were all updated with the supplier code.
Ongoing management of our subcontractors and wider supply chain
Through our subcontractor management system, we introduced new data andperformance reporting requirements during FY24. All subcontractors on our system are
now requested to provide information on their approach and management of humanrights risk, including that of modern slavery.
During FY25, we will further engage with our subcontractors on the issue of humanrights and modern slavery and expand engagement across the top tier of our supplierspend. Our focus will remain on identifying and capitalizing upon opportunities tostrengthen our procedures, enhance visibility, engage and reduce risk. For further
details, refer to the ERM Sustainable Supply Chain Strategy.

11

5. Our partnerships
We take care in forming business relationships so that we honor our standards ofbusiness conduct and ethics. We are required by various laws and regulations toundertake certain due diligence in relation to clients, subcontractors or other third
parties. We comply with the applicable trade sanctions and anti-money launderinglaws. To do this, ERM conducts a due diligence screening process to check those withwhom we seek to form relationships.
In addition to our ongoing internal program of action and work for clients on modern
slavery issues, ERM participates in a number of external engagements and strategicinternational partnerships pertaining to modern slavery and human rights. We act
as advisors to multinational corporations on all issues related to climate change,
human rights, UN Global Compact initiatives, OECD standards, and the Sustainable
Development Goals.
For further information please see ERM’s Human Rights Strategy and Sustainability
Report.

6. Grievance mechanisms and remedying adverse
impacts
Project management model: supporting the delivery of our project work
Our project management model ensures that all ERM work is led by a Partner in Charge(PiC) with the support of a Project Manager (PM). It is the responsibility of the PiC and
PM to ensure that all projects are conducted in accordance with ERM’s policies andprocesses, and pursuant to ERM’s purpose of being a sustainability leader. Should the
Project Management Team have any concerns about the current or future directionof the project, they are required to report these to the client relationship manager,
Business Unit and Legal Counsel, as appropriate.

MODERN SLAVERY STATEMENT 2024

The ERM Helpline
Our reporting system, The ERM Helpline, was implemented in 2018 and is a service
hosted by a third-party provider, Navex. It is available 24 hours a day, 365 days a yearby phone or online and is available in 30 languages. Concerns about our business
operations and any other form of unethical business conduct, including activities
which may negatively impact biodiversity and nature can be reported anonymously in
confidence and without fear of retaliation.
Client concerns
Clients can report concerns through ERM’s client feedback program. The approach
uses a global project and client management tool, Salesforce, to document, internallypublicize, and respond to client feedback. Every project has an identified AccountDirector/Manager and Partner in Charge who are directly accountable and fully
responsible for ensuring client feedback is received and actioned.
A range of stakeholders – including Account Directors, Industry Leaders, Service
Leaders, and Operational Leaders – are engaged in the feedback approach to shareinsights, provide support and respond to client needs. Where warranted, client concerns
are elevated within the organization to assess whether changes are needed within our
quality management system, governing procedures, or training requirements.
Public concerns
Members of the public – individuals and communities – can communicate concerns or
ask questions by emailing businessconduct@erm.com.
RemedyERM is committed to investigating, addressing and remedying where possible andappropriate. We will take all appropriate measures to protect those who raise modern
slavery issues, as set out in our Whistleblowing Policy and issues can be raised
anonymously through the ERM Helpline.

12Our protocol for managing issues raised includes:• Exploration of the issue or concern with the stakeholder who identified it (if known)
and wider operational or project management team (if internal).
• All modern slavery concerns will be escalated internally with appropriate businesspersonnel, including Sustainability, Risk and Legal functions.
• As appropriate, Legal will report to Executive Committee on the issue of concern
and any proposed remediation which has been identified during the course ofinvestigation.
• Where the reported issue involves clients or client contractors and suppliers, the issue
will be explored with the client and remedial measures identified.
• Where appropriate, ERM will engage third parties, including law enforcement
stakeholders to investigate identified potential incidences of modern slavery.
We are committed to addressing any issues promptly but do not put time limits of theduration of time we will take to investigate issues and identify appropriate remedy. We
will, however, maintain engagement with those involved during the course of this time.

7. Reporting
This Statement forms part of our ongoing commitment to transparent and accessible
reporting for the benefit of all stakeholders and reflects our commitment tointernational efforts to abolish all forms of modern slavery. Our wider reporting on
human rights issues, which includes modern slavery, includes:• Annual disclosure of our sustainability performance in our Sustainability Report.
• Our progress in upholding the 10 principles of the UNGC and the Women’s
Empowerment Principles are reported annually via the Communication on Progress
which is published on the UNGC website.
• Our ‘Supporting the SDGs’ document provides a snapshot of ERM’s contribution to
the United Nations Sustainable Development Goals which includes Goal 8.7 on theeradication of all forms of modern slavery.
ERM’s previous published Modern Slavery Statements are available on erm.com.

Tracking and monitoring• We continue to learn more about modern slavery and human rights-related risks
based on direct feedback from our delivery teams. We continue to incorporate thislearning into the corresponding risk tools.
• Throughout FY24, we evaluated how to improve how we track and evaluate theeffectiveness of our responses to actual and potential human rights impact, including
feedback from internal and external stakeholders. We are committed to implementing
effective monitoring and are continuing to work with clients, our supply chain andacross our operations to develop our monitoring framework.
• We are identifying opportunities to better track and monitor human rights
performance across our global operations. In addition to evolving the governance ofour value chain, we are also committed to monitoring performance and will engage tounderstand how best this can be achieved, building on our processes to date.

MODERN SLAVERY STATEMENT 2024

Consultation:
Our policies, programs, and practices are global, and each ERM entity is subject to the same standards of conduct outlined in thisstatement. We have consulted with the relevant entities that we own and control regarding this statement and our approach tohuman rights and modern slavery. This statement has been signed on behalf of all relevant ERM entities by the Group CEO. A fulllist of ERM entities can be found on our website.

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Our priorities for FY25
We will continue to implement our program of action focussed on evolving our governance and management of human rights and modern slavery across our value chain, as set
out in our Human Rights Strategy. The Strategy will be reviewed annually to assess the effectiveness of our governance and further actions will be taken as required to support
our management of modern slavery risk.
We reaffirm and recommit our goal of respect for human rights and a world free of slavery for all. In pursuit of this goal, we will make efforts that extend beyond our own
immediate organizational interests. Alongside setting internal goals, we will continue to participate in building external standards and providing education so that momentum
builds beyond our own sphere of business influence, fully aligned with our purpose of shaping a more sustainable future with the world’s leading organizations.
Area

Targets

Governance

Undertake three regional/sectoral Human Rights due diligence assessments to further understand modern slavery and wider human rights risk in specificgeographies.​

People &Offices

Renew engagement and communications across our operations to enhance employee awareness and active consideration of modern slavery through all our
activities​.
Review and update the Modern Slavery training as appropriate and continue to actively review compliance.
Develop further guidance to specific teams including office management, facilities, procurement and project management personnel on modern slavery
risks.

Services

We will look to embed social advisory work, including modern slavery risk management, within all our service lines.

SupplyChain

Engage the top tier spend of suppliers on human rights to further understand governance and performance across this tier of our supply chain. For further
detail, see ERM’s Sustainable Supply Chain Strategy on erm.com.

Partnerships

Continue our participation in key collaborations such as the WBCSD, UNGC and wider as appropriate.

MODERN SLAVERY STATEMENT 2024

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