ERM Modern Slavery Statement 2019
Note: This Statement is made pursuant to section 54(i) of the UK Modern Slavery Act
2015 and constitutes the Modern Slavery Statement 2019 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 third Modern Slavery Statement andshould be read in conjunction with our previous Statements andour Slavery, Child Labour and Human Trafficking Policy. ERM
continues to be a strong supporter of ethical business conduct inour operations and supply chains and in the international efforts toabolish all forms of modern slavery. Below we describe the specificactions we have taken in the past fiscal year ending 31 March 2019and note plans for the next fiscal year.
1.0 Summary of Actions taken during fiscal year ending 31
March, 2019
In the fiscal year ending 31 March 2019, the specific actions taken
to progress our efforts are as follows:

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Implemented a global anonymous reporting system in August
2018 for all the 42 countries and territories in which weoperate. The reporting system is a multi-lingual service
hosted by a third party provider and is available 24 hours aday, 365 days a year by phone or web portal. With thissystem, concerns about our business operations (including
modern slavery and any other form of unethical businessconduct) can be reported completely anonymously andwithout fear of retaliation;
Rolled out online training for our employees regarding modernslavery;
Finalized our Supplier Code of Business Conduct & Ethics(“Supplier Code”) which will be rolled out to subcontractors andthird party suppliers with updated Terms and Conditions as part ofour supply chain process. Each sets out explicit expectations
and requirements in respect of combatting modern slaveryrisks.
Published and trained personnel on our Subcontractor
Management Policy and centralized our Subcontractor
Auditing Procedure Policy. Both the Subcontractor
Management Policy and our updated, centralized audit
standards address modern slavery and human rights issues.
Continued to update procedures, systems, and data analytics
capabilities related to our own supply chain so that thoseimprovements and information can support our efforts toidentify and abolish all forms of modern slavery along oursupply chain; andIn addition to our work for clients on modern slavery matters,
ERM participated in a number of external engagements andstrategic international partnerships related to modern slavery
in the last year. Examples include: continued participation in
the Working Group on Modern Slavery facilitated by the UK
chapter of the United Nations Global Compact and active
involvement in the development of a WBCSD CEO guide on
Business and Human Rights.

The business of sustainability

2.0 Our Business
ERM is a leading global provider of sustainability consultancy
services, including environmental, health, safety, risk, social andhuman 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 ERMs
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 2019. While
our business is structured on a corporate model and is not apartnership 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 working on 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 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 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 ERM
Sustainability Report 2019.
As part of our work, we also act as advisors to multi-nationalcorporations on human rights, UN Global Compact initiatives,
OECD standards, and the Sustainable Development Goals(SDGs). ERM has seen a significant increase in the work we dowith our clients to help them understand where risks of humanrights abuses may appear in their operations or supply chains,

ERM Modern Slavery Statement 2019

how they can improve their performance to avoid these risks fromoccurring, and/or how they might remedy any cases if discovered.

human rights, and continue to promote and support further efforts
to reduce the risk of modern slavery.

3.0 Our Supply Chain

We reaffirm and recommit to our goal as stated for the last twoyears: 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.

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 last year’s
statement and our description above of what we accomplished thisfiscal year, management of our subcontractors continues to be ourkey supply chain focus.
We acknowledge the challenges of respecting human rights
throughout our supply chain and are committed to working with oursuppliers and business partners to adopt and follow principles andstandards similar to ERM’s, both via our Supplier Code and ourscreening processes.
4.0

Our Policies

Our Slavery, Child Labour and Human Trafficking Policy is inline with the terminology of the Modern Slavery Act. Accordingly, ourpolicy prohibits the use of child or forced labour in our business andany involvement by ERM with organisations that support prohibitedlabour practices or human trafficking. This policy works inconjunction with ERM’s Vision and Values and Code of BusinessConduct and Ethics.

Signed on behalf of the Board of Directors and Executive
Committee:Keryn JamesGroup Chief Executive
Signed: 18 September 2019 for the financial year 2019 (1 April
2018 to 31 March 2019) for ERM Worldwide Group Ltd and its
global subsidiaries

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 2019
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 withfurther details of operational and 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 Supplier Code. Our Partners use ourvision, values, policies, and internal governance arrangements tolead an ERM culture based on sustainability principles, including
fair labour and human rights. Our ability to attract, develop, reward
and retain talented employees is central to our business strategy
and vital to our future. As part of ERM’s corporate Strategy, which
we started rolling out in May 2016, we updated our values toinclude ‘caring for our people’ to underline the absolute priority that
we have always maintained for the safety and health of ouremployees, as well as our strong focus on the growth anddevelopment of our employees. ERM strives to provide a work
environment where all employees have an equal opportunity toreach their full potential and contribute to our success.
5.0 Our Next Steps for the fiscal year ending 31 March 2020
We will provide details on progress made and our performance innext year’s Statement. Until that time, we intend to roll ourSupplier Code out to our supply chain, maintain and enhance
where possible our participation in international forums regarding
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