ERM ModernSlavery
Statement
2022

The business of sustainability

SUPPLEMENTAL INFORMATION| ERM MODERN SLAVERY STATEMENT 2022

ERM Modern Slavery
Statement 2022
Note: This Statement is made pursuant to section 54(i) of the UK Modern Slavery Act 2015 andconstitutes the Modern Slavery Statement 2022 for The ERM International Group Ltd and allof its global subsidiaries. The complete list of ERM subsidiaries as at 31 March 2022 (whichincludes ERM Worldwide Group Limited, Environmental Resources Management Limited, andERM-Europe Limited) can be found here.
This Statement should be read in conjunction with our previous UK Modern Slavery Statements and our HumanRights, Modern Slavery and Child Labor Policy. ERM continues to be a strong supporter of ethical businessconduct in our operations and supply chains and in the international efforts to abolish all forms of modern slavery.
Below we describe the specific actions we have taken in the past fiscal year ending 31 March 2022 and note plans
for the next fiscal year.

1.0 Summary of actions•We implemented our Supplier Code of BusinessConduct & Ethics (“Supplier Code”), which wascompleted last year. This includes specific clauses
around human rights and modern slavery. It has
been rolled out to subcontractors and third party
suppliers. As part of this effort, we updated ourTerms and Conditions as part of our supply chain
process. Our contractual updates bind suppliers
to our Supplier Code and therefore provide explicit
expectations and requirements in respect of
combatting modern slavery risks.

•We have published a new global Sustainable
Procurement Policy, which prioritizes suppliers
that have a public commitment in place to prohibit
slavery in all its forms.

•We see continual improvement as key to oursupply chain approach, and we continued toupdate procedures, systems, and data analytics
capabilities related to our supply chain so that those
improvements and information can support ourefforts to identify and abolish all forms of modern
slavery along our supply chain.

•Given the links between diversity, equity, equality
and inclusion (DE&I) and modern slavery, we believe
it is also relevant to report that we have an Executive
Committee Sponsor, and have appointed regional
DE&I Leads for each of ERM’s four regions. Thisis in addition to a Global Head of DE&I. We also
appointed an Executive Sponsor for Race as part ofour commitment to the Race at Work Charter.

•In addition to our work for clients on modern
slavery matters, ERM participated in a number ofexternal engagements and strategic international
partnerships related to modern slavery in the lastyear. Examples include: active membership of theWorking Group on Modern Slavery in the UN Global
Compact.

In the fiscal year ending 31 March 2022, the specificactions taken to progress our efforts are as follows:••

International anti-money laundering complianceand trade sanctions requirements are key toan international system to combat the money
laundering and humanitarian abuses of the modern
slavery trade. Accordingly, we made significant
updates to our internal anti-money launderingand trade sanction systems, including additional
data capabilities about location risk. By improving
oversight of our operational risk, and especiallypipeline opportunity risk, we can address modern
slavery risk more effectively. We believe that
improving data collection and communication
throughout our organization is particularly importantdue to the fast pace of much of our work, thequick decision-making that this pace entails, andthe corresponding risk measures that must beimplemented. These improvements have been
particularly important as our people start to return
to business-related travel and field work postpandemic.
Due to the fact that many of our employees
continued to work from home due to the pandemic,
we have maintained internal awareness of ourEthics Helpline. We also updated the Ethics Helpline
system for better global coverage and reporting.
As noted previously, our reporting system wasimplemented in calendar year 2018 and is amulti-lingual service hosted by a third party provider
and is available 24 hours a day, 365 days a year byphone or web portal. With this system, concerns
about our business operations (including modernslavery and any other form of unethical businessconduct) can be reported completely anonymously
and without fear of retaliation.

The business of sustainability

SUPPLEMENTAL INFORMATION| ERM MODERN SLAVERY STATEMENT 2022

2.0 Our business
ERM is a leading global provider of sustainability
consultancy services, including environmental, health,safety, risk, social and human rights consulting. We
have more than 170 offices in over 40 countries andterritories. We provide services to clients in many
locations and in all types of industries, with a focus onsustainability across all industry sectors.
The Board of Directors and Executive Committee are
ERM’s highest governing bodies. Our operational andgovernance structure is further detailed on our corporatewebsite. While our business is structured on a corporatemodel and is not a partnership in the legal sense, weuse the term “Partner” to designate our top executivesand leaders. Our Partners lead ERM, and at any giventime, we have between over 7,000 people working on
projects for clients around the world. We provide bothoffice-based services and on-site work all over the world.
Our work takes us to manufacturing plants, construction
sites, mine sites, offshore and onshore rigs, agriculturaland rural areas.
While all ERM Partners are responsible for risk
management across the ERM operations and projects
which they manage, the Group General Counsel andthe legal team provide overall advice and analysis inrespect of ERM’s compliance with applicable laws andregulations (including the UK Modern Slavery Act) andinternal policies and procedures (including ERM’s Codeof Business Conduct & Ethics and our HumanRights, Modern Slavery and Child Labour Policyand oversee any investigation as appropriate. The Group
General Counsel reports to the Group Chief Executive,
who is ultimately accountable to the Board of Directors
for the Group’s management of its risks and compliancein general.
ERM has appointed a new Global Head of Risk who will
focus on companywide risk management which includes
Modern Slavery risks. Their role will include managing
our Enterprise Risk Framework and enhancing, asappropriate, our risk management tools, programs,practices and policies.
Additional support in respect of the Group’s efforts tomanage its Modern Slavery risks and compliance is also
provided by ERM’s Sustainability team and our Chief
Compliance Officer. The remuneration of the Group
General Counsel and the Group Chief Executive is set
by the Board (through its Remuneration Committee)
based against goals and targets which include, inter alia,ensuring compliance and effective risk management.
The Group also publishes supporting data in its annual
Sustainability Report.

The business of sustainability

As part of our work, we also act as advisors to multinational corporations on all issues related to climatechange, human rights, UN Global Compact initiatives,OECD standards, and the Sustainable Development
Goals (SDGs). ERM has seen a significant increase in
the work we do with our clients to help them understandwhere risks of human rights abuses may appear in theiroperations or supply chains, how they can improve theirperformance to avoid these risks from occurring, and/or
how they might remedy any cases if discovered.
As part of our charitable work with the ERM Foundation
supporting the SDGs, we are actively involved
in initiatives aimed at eliminating the economic
disempowerment that drives modern slavery. For more
information, see our ERM Foundation Annual Review
2022.

3.0 Our supply chain
Because ERM is a services company and not a products
company, we focus our modern slavery efforts on
subcontracted services as they are our primary supply
chain. As noted in our description above of what weaccomplished this fiscal year, management of oursubcontractors continues to be our key supply chain
focus.
We acknowledge the challenges of respecting humanrights throughout our supply chain and are committed
to working with our suppliers and business partners
to adopt and follow principles and standards similar
to ERM’s, both via our Supplier Code, our Sustainable
Procurement Policy and our screening processes.

4.0 Our policies
Our Human Rights, Modern Slavery and Child
Labour Policy is in line with the terminology of theModern Slavery Act. Accordingly, our policy prohibits
the use of child or forced labor in our business and any
involvement by ERM with organizations that support
prohibited labor practices or human trafficking. This
policy works in conjunction with ERM’s Purpose andValues and Code of Business Conduct and Ethics.
ERM’s Sustainability Policy and Sustainability
Approach articulate our commitments to sustainability,and ERM became a signatory of the UN Global
Compact in 2011. As part of our ongoing support
for the protection of international human rights, wehave continued to use our UN commitment and otherinternational developments as a basis to improve ourpolicies, procedures, and approach to business.

SUPPLEMENTAL INFORMATION| ERM MODERN SLAVERY STATEMENT 2022

Our policy framework and corporate governancedisclosures are mapped in ERM’s 2022 Sustainability
Report to the Global Reporting Initiative (GRI)
Index and also to the Ten Principles of the UN Global
Compact, which include points on anti-corruption andhuman rights, along with further details of operationaland governance structure.
Our commitment to continued improvement of our
supply chain was noted earlier in reference to our new
Subcontractor Management Policy, new centralized
subcontractor auditing procedure, and our new SupplierCode. Our Partners use our purpose, values, policies,
and internal governance arrangements to lead an ERM
culture based on sustainability principles, including fairlabor and human rights.
Our ability to attract, develop, reward and retain talented
employees is central to our business strategy and vitalto our future. The values contained in ERM’s corporate
strategy, including ‘caring for our people’, underline theabsolute priority that we have always maintained for thesafety and health of our employees, as well as our strong
focus on the growth and development of our employees.
ERM strives to provide a work environment where all
employees have an equal opportunity to reach their fullpotential and contribute to our success.

We reaffirm and recommit to our goal as stated forthe last three years: ERM is committed to the goal ofrespect for human rights and a world free of slavery,
and in furtherance of this goal, we will make efforts
that extend beyond our own immediate organizational
interests. Not only will we continue to set internalgoals, we will also participate in building external
standards and providing education so that momentum
not only builds in our sphere of business influence
but beyond, fully aligned with our purpose of shaping
a more sustainable future with the world’s leadingorganizations.

Signed on behalf of the Board of Directors andExecutive Committee:
Thomas Reichert
Group Chief Executive
Signed: 21 June 2022 for the financial year 2022
(1 April 2021 to 31 March 2022) for The ERM
International Group Ltd and its global subsidiaries.

5.0 Our next steps for the fiscal year ending
31 March 2023
We will provide details on progress made and ourperformance in next year’s statement. We will alsoprovide a refresher training on modern slavery to ourtop leadership and begin to report on modern slavery
training statistics. We will update both our project risk
review system and our travel approval system as tomodern slavery risk. We will also perform {at least one}geographical modern slavery risk assessment and reporton those findings. As part of our DE&I program, wewill identify DE&I goals that support our efforts against
modern slavery.
Further, as is our normal practice, we will maintain andenhance where possible our participation in internationalforums regarding human rights, and continue to promoteand support further efforts to reduce the risk of modernslavery.

The business of sustainability© Copyright 2022 by The ERM International Group Limited and/or its affiliates(‘ERM’). All Rights Reserved. No part of this work may be reproduced ortransmitted in any form or by any means, without prior written permission ofERM