ERM Modern Slavery Statement 2020
Note: This Statement is made pursuant to section 54(i) of the UK Modern Slavery Act
2015 and constitutes the Modern Slavery Statement 2020 for ERM Worldwide GroupLtd and all its global subsidiaries. The complete list of ERM subsidiaries (whichincludes Environmental Resources Management Limited, ERM-Europe Limited andEmerald 2 Limited) is available for download here.
This Statement is ERM’s fifth Modern Slavery Statement andshould be read in conjunction with our previous Statements andour Slavery, Child Labour and Human Trafficking Policy. Thisstatement and all past statements can be accessed via a link on ourpublic website, erm.com. ERM continues to be a strong supporterof ethical business conduct 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 2020 and note plans for thenext fiscal year.
1.0 Summary of Actions taken during fiscal year ending 31March, 2020
We progressed our Supplier Code as referenced in last year’sstatement, but did not complete the rollout across our supply chain
by 31 March 2020. Due to the subsequent operational impacts of
Covid-19 our rollout has been further delayed, but as at the date ofthis statement is planned to be completed by December 2020.
During the year, we took other specific actions to progress ourefforts against Modern Slavery, as follows:

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Improved our due diligence process by linking automatic firstlevel anti-money laundering, trade sanction and compliancescreening to our project opportunity database. Our
improvements allow screening information to flow to project
teams at the earliest discussion of a project. Sinceinternational sanctions are the primary way to shut downmoney laundering from modern slavery, our system
improvements not only improve our commercial agility but also
support our ethical commitments in business relationships.
Implemented a broad based training programme for ourpersonnel regarding safe and ethical management ofsubcontractors, especially designed for high risk activities andjurisdictions;
Developed and piloted new training for our project managers(as they are “front line” for spotting and reporting concerns),
plus we set in motion an aggressive plan to launch this new
training across the global business; andIn addition to our work for clients to support their efforts
against modern slavery, ERM also participated in a number ofexternal engagements and strategic international partnerships
related to modern slavery in the last year, including with the UN
Global Compact Working Group and WBCSD. For example,
our CEO Keryn James was one of the 35 forward-thinking top
executives of WBCSD member companies who signed andpromoted the WBCSD CEO Guide on Human Rights andBusiness in 2019.

2.0 Our Business
ERM is a leading global provider of sustainability consultancy
services, including environmental, health, safety, risk, social andThe business of sustainability

human rights consulting. As a professional services firm that hasoperated for almost half a century, our people are our greatest
asset. We have more than 160 offices in over 40 countries andterritories. We provide services to clients in many locations andin all types of industries, with a focus on the following key sectors:
Oil and Gas, Mining, Power, Manufacturing, Technology, MediaandTelecommunications, Chemical and Pharmaceutical, andBanking and Finance.
The Board of Directors and Executive Committee are ERM's
highest governing bodies. Our operational and governancestructure is further detailed on erm.com in the section about
us/who we are and in our ERM Sustainability Report 2020.
While our business is structured on a corporate model and is nota partnership in the legal sense, we use the term “Partner” todesignate our top executives and leaders. Approximately 550
Partners lead ERM, and at any given time, we have between
5,000 to 5,500 people supporting projects for clients around theworld. We provide both office-based services and on-site work allover the world. Our work takes us to manufacturing plants,
construction sites, mine sites, offshore and onshore rigs,
agricultural and rural areas.
While all ERM Partners are responsible for risk management
across the ERM operations and projects which they manage,
the Group General Counsel and his team provide overall
advice and analysis in respect of ERM’s compliance withapplicable laws and regulations (including the Modern SlaveryAct) and internal policies and procedures (including ERM’s
Code of Business Conduct & Ethics and our Slavery, Child
Labour and Human Trafficking Policy) and oversee anyinvestigation 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 compliance in general. Additional
support in respect of the Group’s efforts to manage its Modern
Slavery risks and compliance is also provided by ERM’s
Sustainability team. The remuneration of the Group GeneralCounsel and the Group Chief Executive is set by the Board(through its Remuneration Committee) based against goals andtargets which include, inter alia, ensuring compliance andeffective risk management. The Group also publishes
supporting data in its annual Sustainability Report – see ERM
Sustainability Report 2020.
As part of our work, we also act as advisors to multi-national
corporations on human rights, UN Global Compact initiatives,
OECD standards, and the Sustainable Development Goals(SDGs).
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. By way of example, we invest in women-led agricultural
cooperatives and fund training and support for women-owned
clean water businesses. For more information, see our ERM

ERM Modern Slavery Statement 2020

Foundation Annual review at ERM Foundation 2020 AnnualReview.

Signed on behalf of the Board of Directors and Executive
Committee:

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. We focused our training efforts
on subcontractor management in general and project managers inparticular.

Keryn JamesGroup Chief Executive
Signed: 29 September 2020 for the financial year 2020 (1 April2019 to 31 March 2020) for ERM Worldwide Group Ltd and its
global subsidiaries

In FY19, we designed a refreshed training program forsubcontractor management and for project management, andduring early FY20, we piloted and commenced the delivery of thistraining. During FY20, of the average target cohort ofapproximately 1,400 employees, we trained over 600 people (over40% attendance). As at the date of this statement, we areprogressing toward our target to train the remainder of the target
cohort.
3.0 Our Policies
Our Slavery, Child Labour and Human Trafficking Policy is inline with the terminology of the Modern Slavery Act. Accordingly,
our policy prohibits the use of child or forced labour in our businessand any involvement by ERM with organisations that support
prohibited labour practices or human trafficking. This policy works inconjunction with ERM’s Vision and Values and Code of BusinessConduct and Ethics.
ERM’s Sustainability Policy and Sustainability Approacharticulate our commitments to sustainability, and ERM became asignatory of the UN Global Compact in 2011. As part of our ongoingsupport for the protection of international human rights, we havecontinued to use our UN commitment and other international
developments as a basis to improve our policies, procedures, andapproach to business. Our policy framework and corporate
governance disclosures are mapped in ERM’s 2020 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 and human rights, along with further detailsof operational and governance structure.
4.0 Our Next Steps for the fiscal year ending 31 March 2021
We will provide details on progress made and our performance innext year’s Statement. Until that time, we intend to complete theroll out of our Supplier Code to our supply chain, maintain andenhance where possible our participation in international forums
regarding human rights, and continue to promote and support
further efforts to reduce the risk of modern slavery.
We reaffirm and recommit to our goal as stated for the last threeyears: ERM is committed to the goal of respect 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 internal goals, we will
also participate in building external standards and providing
education so that momentum not only builds in our sphere ofbusiness influence but beyond, fully aligned with our purpose ofshaping a more sustainable future with the world’s leadingorganisations.

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