ERM Modern Slavery Statement 2021
Note: This Statement is made pursuant to section 54(i) of the UK Modern Slavery Act
2015 and constitutes the Modern Slavery Statement 2021 for ERM Worldwide GroupLtd and all its global subsidiaries. The complete list of ERM subsidiaries as at 31
March 2021 (which includes Environmental Resources Management Limited, ERMEurope Limited and Emerald 2 Limited) is available for download {here}.
This Statement should be read in conjunction with our previous UK
Modern Slavery Statements and our Slavery, Child Labour andHuman Trafficking Policy. ERM continues to be a strong
supporter of ethical business conduct in our operations and supply
chains and in the international efforts to abolish all forms ofmodern slavery. Below we describe the specific actions we havetaken in the past fiscal year ending 31 March 2021 and note plans
for the next fiscal year.
1.0 Summary of Actions taken during fiscal year ending 31
March, 2021
In the fiscal year ending 31 March 2021, the specific actions taken
to progress our efforts are as follows:

■

■

■

■

International anti-money laundering compliance and trade
sanctions requirements are key to an international system tocombat the money laundering and humanitarian abuses of themodern slavery trade. Accordingly, we made significant
updates to our internal anti-money laundering and trade
sanction systems, including additional data capabilities aboutlocation risk. By improving oversight of our operational risk,
and especially pipeline opportunity risk, we can address
modern slavery risk more effectively. We believe that
improving data collection and communication throughout ourorganization is particularly important due to the fast pace ofmuch of our work, the quick decision making that this paceentails, and the corresponding risk measures that must beimplemented. We believe that these improvements will beparticularly important as our people return to “in the field, inthe office” travel post-pandemic.
Due to the fact that many of our employees did not go to aphysical office due to the pandemic, we broadened internal
communications on our Helpline. We also updated theHelpline system for better global coverage and reporting. As
noted previously, our reporting system was implemented incalendar 2018 and is a multi-lingual service hosted by a third
party provider and is available 24 hours a day, 365 days ayear by phone or web portal. With this system, concerns
about our business operations (including modern slavery andany other form of unethical business conduct) can be reported
completely anonymously and without fear of retaliation;
We finalized and published our Supplier Code of BusinessConduct & Ethics (“Supplier Code”), which includes specificclauses around human rights and modern slavery, and rolled itout to subcontractors and third party suppliers. As part of thiseffort, we updated Terms and Conditions as part of our supply
chain process. Our contractual updates bind suppliers to ourSupplier Code and therefore provide explicit expectations andrequirements in respect of combatting modern slavery risks.
We see continual improvement as key to our supply chain
approach, and we continued to update procedures, systems,

The business of sustainability■■

and data analytics capabilities related to our supply chain sothat 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 and Inclusion (DE&I)
and Modern Slavery, we believe it is also relevant to reportthat we appointed a formal head of DE&I for ERM globally.
In 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: active membership of theWorking Group on Modern Slavery in the UN Global Compact;
participation in a World Environment Center human rights
forum, an international anti-money laundering/trade sanctions
forum in Berlin, and a supply chain forum with Anti-Slavery
International.

2.0 Our Business
ERM is a leading global provider of sustainability consultancy
services, including environmental, health, safety, risk, social andhuman rights consulting. This year is our 50th anniversary, and as
a professional services firm that has operated for half a century,
we are well prepared to aid our clients on their sustainability journey
going forward. We have more than 160 offices in over 40
countries and territories. 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 and governancestructure is further detailed on erm.com in the section
about/company/leadership and in our ERM Sustainability
Report 2021. While our business is structured on a corporatemodel and is not a partnership in the legal sense, we use the term“Partner” to designate our top executives and leaders. OurPartners 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 UK Modern
Slavery Act) 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

ERM Modern Slavery Statement 2021

management of its risks and compliance in general. Additional
support in respect of the Group’s efforts to manage its ModernSlavery 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 RemunerationCommittee) 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.
As part of our work, we also act as advisors to multi-national
corporations on all issues related to climate change, humanrights, UN Global Compact initiatives, OECD standards, and theSustainable Development Goals (SDGs). ERM has seen asignificant increase in the work we do with our clients to help
them understand where risks of human rights abuses may
appear in their operations or supply chains, how they can
improve their performance 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 modernslavery. For more information, see our ERM Foundation Annual
Review 2021.
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 we accomplished this fiscal year, management of
our subcontractors continues to be our key 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 Purpose and Values and Code ofBusiness Conduct 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 2021 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.
www.erm.com

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 ourpurpose, 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. The values contained in ERM’s corporate
Strategy, including ‘caring for our people’, underline the absolutepriority that we have always maintained for the safety and health of
our employees, 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 2022
We will provide details on progress made and our performance innext year’s Statement. Our plans include making our Modern
Slavery Statement a part of our Sustainability Report and changing
our reporting date to earlier in line with that change. We will also
provide a refresher training on modern slavery to our top
leadership and begin to report on modern slavery training statistics.
We will update both our project risk review system and our travelapproval system as to modern slavery risk. We will also perform{at least one} geographical modern slavery risk assessment andreport on those findings. As part of our DE&I programme, we will
identify DE&I goals that support our efforts against modern slavery.
Further, as is our normal practice, we will maintain and enhance
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.
Signed on behalf of the Board of Directors and Executive
Committee:
Keryn JamesGroup Chief Executive
Signed: 27 September 2021 for the financial year 2021 (1 April
2020 to 31 March 2021) for ERM Worldwide Group Ltd and its
global subsidiaries

2© Copyright 2021 by ERM Worldwide Group Limited and/or its affiliates (‘ERM’).
All Rights Reserved. No part of this work may be reproduced or transmitted
in any form or by any means, without prior written permission of ERM.