MODERN SLAVERY ACTTRANSPARENCY STATEMENTOCTOBER 2016
This is a statement of the steps that
Clifford Chance has taken to ensurethat slavery and human trafficking are
not taking place in our business or in
our supply chains. This statement is forthe financial year ending 30 April 2016,
in accordance with section 54 of theModern Slavery Act 2015.

OUR VALUESAs a leading global law firm we are rightly
held to high standards in all we do.
We believe that our licence to operate,
the sustainability of our business andthe achievement of our aim to be thelaw firm of choice for the world’s leadingbusinesses are dependent on our ability
to inspire trust and earn the confidenceof all our stakeholders. To do this wemust act responsibly, creating long-termvalue and supporting their future success.
This includes supporting the objectives ofthe Modern Slavery Act 2015.

BUSINESS, ORGANISATIONALSTRUCTURE AND
SUPPLY CHAINS
Clifford Chance is an integrated
international law firm which provides legal
services across the key markets of theAmericas, Asia Pacific, Europe, the Middle
East and Africa. We have 35 offices in
25 countries, focusing on the core areasof commercial activity - capital markets;
corporate and M&A; finance and banking;real estate; tax, pensions and employment,and litigation and dispute resolution.
The firm is led by about 550 partners, witha total headcount of around 6,000 including
lawyers and business services staff.
Our principal partnership is Clifford Chance
LLP, a limited liability partnershipincorporated under English law. In somejurisdictions we practise through thispartnership, in others through a local entity
which uses the Clifford Chance name.
Our practices are supported by a numberof wholly-owned service companies.
The members, shareholders, partners anddirectors of all these entities are subject
to the governance of Clifford Chance LLP.
Each of the 35 offices is managed locally
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by one of our senior partners, supported
by professional managers and experts
as appropriate. For more information
about us, our business and our structure,see Who we are and how we work.

have agreed to support and respect
internationally recognised human rights,
both as part of our commitment to theUN Global Compact and consistent withthe UN Guiding Principles.

Our supply chains relate to our global
office-based professional service business– supplying personnel, goods and services
to support the services we in turn supply
to our clients. Some of our suppliers
are engaged on a global basis; others
are local. We carry out due diligence on
new suppliers, and seek to establish andmaintain relationships with our supplierswith a view to ensuring that all elements ofour supply chain act in accordance withapplicable laws, our values and ethicalbusiness principles.

Our employment and labour practices
reinforce our approach to modernslavery. We create a safe, healthy andinclusive workplace with a strong cultureof collaboration and respect for others.
This is underpinned by a number ofpolicies relating to diversity, dignity andinclusiveness which reflect a businessenvironment in which our ethical values
are promoted and we adhere to allapplicable laws in all jurisdictions in which
we operate. For some of our practices andinitiatives, see People & inclusion.

POLICIES

DUE DILIGENCE ANDRISK ASSESSMENT

Clifford Chance has a global policyrelating to slavery and human trafficking.
Clifford Chance opposes all forms ofslavery and human trafficking, and we arecommitted to taking steps to ensure thatthese do not occur in our business or in
our supply chains.
Our modern slavery policy is part of a suiteof policies affirming our commitment
to responsible, sustainable and ethicalbusiness. In 2009, we signed theUN Global Compact as a demonstrationof our commitment to help advancesustainable business models and markets
with a view to creating a more sustainable
and inclusive global economy. We activelysupport the UN Global Compact’s 10
principles focusing on the core areas ofhuman rights, labour, the environment
and anti-corruption and report annuallyon our compliance: see our Responsible
Business report and our Global Reporting
Index. We also have a global human rights
policy as follows:
The UN Guiding Principles on Businessand Human Rights which wereunanimously endorsed by the HumanRights Council in 2011 state that all
business enterprises have a responsibility
to respect human rights. As a firm we

In early 2016, we commenced theprocess of reviewing Clifford Chance’sbusiness and supply chains to identify
and assess the risk of slavery and humantrafficking in each of those areas, themeasures already in place to address
such risks, and any additional measuresthat may be warranted in light of thereview. As a professional services firm
strictly regulated by professional regulatory
bodies in each of the jurisdictions in which
we operate, and in the light of our global
employment and ethical policies andpractices, we have assessed that we areat low risk of slavery or human trafficking
existing within our own business, althoughwe have taken steps through our policies
and training in particular to seek to ensure
we are alert to possible risks of modern
slavery in our business, and prepared toaddress any that may arise. We consider
there is a greater risk of slavery or humantrafficking occurring within our supply
chains (including suppliers of personnel,goods and services).
We acknowledge that slavery and humantrafficking exist in many jurisdictions inwhich we operate, and/or from which
we procure goods or services, andaccordingly are implementing measuresdescribed in this statement that aredesigned to facilitate the identification of
any relevant issues that may arise, andensure they are addressed appropriately.
We have developed an approach todue diligence which extends to both ourbusiness and our supply chains, and are
implementing further steps to address therelevant risks within both.
Our ongoing due diligence comprises:
n a local review of each office, as partof which responsible managers arerequired to consider whether theiroffice might, directly or indirectly, beassociated with any suppliers which
may be particularly susceptible toslavery or human trafficking, and tohighlight any concerns. Our central risk
management team will then work with
our local offices to address any issues
that arise; andn a central risk-based assessment of ourcurrent supply arrangements globallywith a view to enhancing existingarrangements where appropriate, tofurther ensure that slavery and modern
slavery may not occur within our
supply chain.

PROCUREMENT PROCESSES
Alongside conducting a risk-based review
of our existing supply chains, we are taking
steps to build and expand a frameworkspecifically to address the risk of slavery
and human trafficking as follows:n We have developed a supplierquestionnaire designed to assess

the risk of slavery and humantrafficking in the business and supply
chains of a proposed supplier prior
to entering into any new supply
relationships. This questionnaire will
also be applied prior to the renewal ofexisting supply contracts.
n We have developed a process toensure that appropriate contractual
provisions are incorporated into new
supplier contracts and renewals ofexisting contracts, which as a minimum
require a supplier to take stepsto ensure that slavery and humantrafficking are not taking place in its
business or in its supply chains, and,
where appropriate:•

require a supplier to establish
processes and policies to ensurethat slavery and human trafficking
are not taking place in its businessor in its supply chains,•enable us to obtain information toverify compliance (including by thecommissioning of independent thirdparty audits); and•enable us to terminate the contract
for breach of these requirements,
though if an issue does arise weintend where possible to engage
with the supplier in question andencourage or assist the supplier totake appropriate steps to mitigate
or remedy the issue.

that sets out the standard of conduct
Clifford Chance expects from all oursuppliers and contractors worldwide
and which covers slavery and humantrafficking. In order to assess effectivenessof our measures in ensuring that slavery
and human trafficking are not taking placein the firm’s business or supply chains, weplan to develop procedures for monitoring
compliance and implement appropriate
performance indicators.

TRAINING, AWARENESS ANDCAPACITY BUILDING
We are committed to ensuring that
Clifford Chance personnel are equipped
to identify risk factors and indicators ofpossible slavery and human trafficking,understand the implications of theModern Slavery Act for our business, andreact appropriately:n We have developed and deployed amandatory training module for all ourlawyers, including all our partners,
in relation to the issues the ModernSlavery Act raises for Clifford Chanceand its businessn We have also developed and deployedspecific targeted training for groupsof our business services staff, suchas the teams involved in procurement
and human resources, in relation to theissues relevant to their areas of work
for Clifford Chance.

We have developed a Supplier Codeof Conduct available on our website

This statement is made by Clifford Chance LLP on behalf of itself and those entities which operate as part of the Clifford Chancegroup and are subject to the governance of Clifford Chance LLP (“Clifford Chance”).

SIGNED

DATE…………………………

25/10/2016……………………

MATTHEW LAYTONManaging Partner, Clifford Chance LLP
for and on behalf of Clifford Chance
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