ERM SUSTAINABILITY REPORT 2O23

Modern slavery
statement 2023
SUPPLEMENT

Sustainability is our businessERM | Modern slavery statement 2023

ERM Modern Slavery Statement 2023
1.0 Summary of actions

Note: This Statement is made pursuant to section 54(i)of the UK Modern Slavery Act 2015 and constitutes
the Modern Slavery Statement 2023 for The ERM
International Group Ltd and all of its global subsidiaries.
The complete list of ERM subsidiaries as of 31 March2023 (which includes 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 Human Rights, Modern
Slavery and Child Labor 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 of modern
slavery. In this statement, we describe the specific actions we havetaken in the past fiscal year ending 31 March 2023 and note plans forthe next fiscal year.

In the fiscal year ending 31 March 2023, the specific actions taken to progress
our efforts are as follows:• We have continued to develop our governance, strategy and processes foridentifying and managing risk, including that of modern slavery. This hasincluded a review of the process by which we identify, assess and address
risk both within our own operations and that of our supply chain.
• We have undertaken a detailed analysis of evolving best practice in themanagement of human rights and modern slavery. This has been used todevelop a program of action, which we have begun executing in fiscal year
2023 and will continue to deliver throughout fiscal year 2024.
• The analysis has been used to further evolve our Human Rights, Modern
Slavery and Child Labor Policy, which has been informed by our subject
matter experts.
• To ensure our workforce is alert to, and informed of, human rights andmodern slavery issues, we have developed and rolled out mandatory training
to all those in a position of responsibility for managing our own operations
and those of our work with clients. As of the 31 March 2023, 76% of thoseascribed the training have completed the course, and a system of reminders
is in place to improve the response rate. We will refresh the training, in linewith identified need, and mandate training for relevant new joiners, as well as
refresher training for existing employees.

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ERM | Modern slavery statement 2023

• As part of the mandatory training program, there has been increased
awareness and empowerment of employees to report any suspicions ofhuman trafficking or modern slavery via our Ethics helpline, email and/or established governance systems that include compliance, legal andsustainability leads.
• As noted previously, our reporting system was implemented in calendar
year 2018 and is a multi-lingual service hosted by a third-party provider. Itis available 24 hours a day, 365 days a year by phone or web portal. With
this system, concerns about our business operations (including modernslavery and any other form of unethical business conduct) can be reported
completely anonymously and without fear of retaliation.
• We have implemented our updated Supplier Code of Business Conduct& Ethics (“Supplier Code”), which includes specific clauses around humanrights and modern slavery. It has been rolled out to subcontractors and thirdparty suppliers. Our contractual Terms & Conditions also bind suppliers to ourSupplier Code and therefore provide explicit expectations and requirements in
respect of addressing modern slavery risks.
• We have implemented the new global Sustainable Procurement Policy,
developed in fiscal year 2022, which prioritizes suppliers that have a publiccommitment in place to prohibit slavery in all its forms.
• We see continual improvement as key to our supply chain approach, and wehave continued to update procedures, systems and data analytics capabilities
related to our supply chain so that those improvements and information can
support our efforts to identify and abolish all forms of modern slavery along
our supply chain. We will further engage and seek to actively monitor oursupply chain with respect to their governance of human rights and modern
slavery within their own operations during fiscal year 2024.

• In addition to our ongoing program of action and work for clients on modern
slavery matters, ERM has participated in a number of external engagements
and strategic international partnerships related to modern slavery in the lastyear. Examples include:– Active membership of the Working Group on Modern Slavery in the UN
Global Compact in the United Kingdom; and– ERM is a member of the Business Commission for Tackling Inequality(BCTI). ERM supported the launch of the BCTi’s flagship report and will bepart of the corporate action to address rising inequality.

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 havemore than 150 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 governance structure is further detailed on ourcorporate website. While our business is structured on a corporate model andis not a partnership in the legal sense, we use the term “Partner” to designate
our top executives and leaders. Our Partners lead ERM, and as of the end of
the fiscal year, we have over 8,000 people working on projects for clients aroundthe world. We provide both office-based services and on-site work all over theworld. Our work takes us to manufacturing plants, construction sites, mine sites,
offshore and onshore rigs, agricultural and rural areas.

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ERM | Modern slavery statement 2023

While all ERM Partners are responsible for risk management across the ERM
operations and projects that they manage, the Group General Counsel and thelegal team provide overall advice and analysis in respect of ERM’s compliancewith applicable laws and regulations (including the UK Modern Slavery Act) andpublished policies and procedures (including ERM’s Code of Business Conduct& Ethics and our Human Rights, Modern Slavery and Child Labor Policy andoversee any investigation as appropriate. The Group General Counsel reports
to the Group Chief Executive, who is ultimately accountable to the Board ofDirectors for the Group’s management of its risks and compliance in general.
ERM’s Global Head of Risk is responsible for managing companywide
risk, which includes Modern Slavery risks. Their remit includes managing
our Enterprise Risk Framework and enhancing, as appropriate, our risk
management tools, programs, practices and policies. Additional support
in respect of the Group’s efforts to manage its Modern Slavery risks andcompliance is also provided by ERM’s Sustainability team and our Chief
Compliance Officer.

OECD standards and the Sustainable Development Goals (SDGs). ERM has
seen a significant increase in the work we do with our clients to help themunderstand 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.

3.0 Our supply chain
Because ERM is a services company, we focus our modern slavery efforts on
subcontracted services as they are our primary supply chain. As noted in ourdescription above of what we accomplished this fiscal year, management of oursubcontractors 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 our suppliers and business partners toadopt and follow principles and standards similar to ERM’s, via our Supplier Code,our Sustainable Procurement Policy and our screening processes.

4.0 Our policies
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 publishes supporting data in its annual Sustainability Report.
As part of our philanthropic work with the ERM Foundation supporting theSustainable Development Goals, we are actively involved in initiatives aimed ateliminating the economic disempowerment that drives modern slavery. For more
information, see our ERM Foundation Annual Review 2023.
As part of our work, we also act as advisors to multinational corporations on allissues related to climate change, human rights, UN Global Compact initiatives,

Our Human Rights, Modern Slavery and Child Labor Policy has been further
updated to align with emerging best practice. 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 and Beliefs and Code ofBusiness Conduct and Ethics.
ERM’s Sustainability Policy and Sustainability Approach articulate ourcommitments to sustainability, and ERM became a signatory of the UN
Global Compact in 2011. As part of our ongoing support for the protection ofinternational human rights, we have continued to use our UN commitment andother international developments as a basis to improve our policies, procedures
and approach to business.

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ERM | Modern slavery statement 2023

Our policy framework and corporate governance disclosures are mapped in
ERM’s Sustainability Report 2023 Global Reporting Initiative (GRI) Indexand in ERM’s Communication of Progress to the UN Global Compact. We
report our performance in respect of the UN Global Compact, including thatpertaining to human rights, annually via the Communication on Progress, which
is published on the UN Global Compact website.
Our commitment to continued improvement of our supply chain was noted
earlier in reference to our new Subcontractor Management Policy, centralized
subcontractor auditing procedure and our Supplier Code. Our Partners use ourpurpose, values, policies and internal governance arrangements to support ourworking culture based on sustainability principles, which includes fair labor andequal treatment for all.

• We will undertake a geographical modern slavery risk assessment and reporton those findings.
Further, as is our normal practice, we will maintain and enhance where possible
our participation in international forums regarding human rights and continue topromote and support further efforts to reduce the risk of modern slavery.
We reaffirm and recommit to our goal of respect for human rights and a world
free of slavery for all. 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 of business influence but beyond, fully aligned with our purpose ofshaping a more sustainable future with the world’s leading organizations.

5.0 Our next steps
We will provide details on progress made and our performance in next year’sstatement. As noted in the Summary of Actions section, we will continue toimplement our program of action focused on evolving our governance andmanagement of human rights and modern slavery. Key actions within thisprogram, to be delivered in fiscal year 2024, include:• We will evolve and publish ERM’s strategy on Social Impact and HumanRights, which will cover our global operations.
• We will continue to develop our enterprise risk management processes
specifically in relation to human rights and modern slavery. This includes
evolving our project selection and risk management processes.
• We will review our supply chain management to address specific potential
modern slavery issues in different locations.
• We will evolve, as appropriate, and continue to roll out mandatory training toall new employees occupying a role in managing suppliers and contractors
and refresh training to existing employees in this role.

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

Thomas Reichert
Group Chief Executive
Signed: 30 June 2023 for the fiscal year 2023
(1 April 2022 to 31 March 2023) for The ERM International Group Ltd
and its global subsidiaries.
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Photo credit:
Nicholas Miller,
United States

ERM SUSTAINABILITY REPORT 2O23

Modern slavery
statement 2023
SUPPLEMENT© Copyright 2023 by The ERM International 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 priorwritten permission of ERM.

Sustainability is our business