Modern Slavery Statement
Under the Modern Slavery Act 2018 (Cth)K&L Gates (ABN 81 310 965 026)

Reporting Period
1 January 2023 – 31 December 2023

K&L GATESINTRODUCTIONINTRODUCTION
K&L Gates ABN 81 310 965 026 (K&L Gates, we, us, our or Reporting Entity) is pleased to present
our fourth Modern Slavery Statement (Statement) made pursuant to the Modern Slavery Act 2018(Cth) (Act).
We are committed to opposing modern slavery in all its forms and acting in an ethical manner, with integrity andtransparency in all of our business dealings. As part of this commitment, we have prepared this Statement to outline theactions taken by K&L Gates in 2023 to fulfil our strategy to assess, identify and mitigate the risk of modern slavery in ouroperations and our supply chains.

With support from specialists and technology providers within the modern slavery space, we undertook a detailed analysisof the risk of modern slavery in our operations and our supply chains. Whilst the results were positive with indications of alow risk of modern slavery, we have taken proactive steps to mitigate and minimise the risk of modern slavery and willcontinue our efforts to further reduce modern slavery risk in the coming years.
We continue to uphold our high standards of professionalism, ethical behaviour and integrity in everything we do. Thisextends not only to providing our clients with an unwavering standard of excellence in legal services, but also to positively
contributing to the wellbeing of communities around the world. This Statement covers the initiatives implemented by K&L
Gates to reduce the risk of modern slavery occurring as a result of the changing nature of our workforce, hybrid working,client engagement preferences and our actions more broadly.

K&L Gates is committed to the reduction of modern slavery risk and will continually strive to improve its approach. We willcontinue to monitor metrics and formulate initiatives to ensure we conduct our business operations in an ethical manner.

This Statement has been prepared under my supervision (with oversight by the Australian Board), and by our senior
management team in consultation with external subject matter experts. This Statement has been duly approved by the
K&L Gates Australiap-^oard, in its capacity as the principal governing body of K&L Gates, for lodgement in accordancewith theTequirerphnts of the Act.

Jason Opperman
Managing Partner, Australia, K&L Gates

Member, K&L Gates Australian Board

On behalf of the K&L Gates Australian Boardand as a Responsible Member (as defined in the Act) of the Reporting Entity
28 June 2024

K&L Gates | Modern Slavery Statement - Financial Year 2023 | 2

K&L Gates | Modern Slavery Statement – Financial Year 2023 | 2

EXECUTIVE SUMMARY
Area

Actions Completed

Reporting Criteria
Assessed

Identified the Reporting Entity and any controlled entities.
Described our structure, operations and supply chain.

1 and 2

Reviewed current policies and procedures to ensure they reflect ourcommitment to addressing modern slavery.
Started the process of implementing a supplier onboarding andengagement process.

3 and 4

Categorised direct suppliers based on industry and geography tounderstand our risk profile.
Mapped and assessed our comprehensive supply chain.
Performed in-depth analysis on identified elevated risk industries toinform future due diligence.

3 and 4•

Implemented our Speak Up Policy (Whistleblower Policy) for thereporting of unethical conduct including occurrences of modern
slavery.

3 and 4•

Conducted Continuing Professional Development (CPD) sessions forlawyers and clients.

3 and 4•

Established protocols for safe working conditions both on-site andremotely.
Ensured safe transition to work-from-home and back to the office andcontinued "K&L Gates Konnect" breakfasts.

3, 4 and 7•

Established our regular review process on an annual and ongoingbasis to measure our modern slavery risk in our supply chain.

5•

Engaged with key personnel across our business units to ensure a
unified and consistent approach.

6 and 7••

Entities and Structure•

Policies and Protocols•••

Due Diligence•

Remediation

Training and
Education

Post COVID-19•

Assessing Efficiency

Collaborative Efforts

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OVERVIEW
Corporate Structure and Workforce

REPORTING ENTITY
K&L Gates is the reporting entity for the purposes ofsection 5(1) of the Act. The Statement is presented on aconsolidated basis by K&L Gates and its controlled entities.
For the purposes of this Statement, our structure includes
the following entities:

K&L Gates (ABN 91 310 965 026)



MMB Property Services Pty Ltd.

K&L Gates is an Australian partnership. As a professional
services provider, we predominantly employ professionallyqualified and highly skilled people. As at 31 December
2023, K&L Gates had approximately 460 partners andemployees in Australia in both legal and non-legal roles
across our operations.

Governance

MMB Management Services Pty Ltd(ABN 25 837 078 022)

REPORTING PERIODThis Statement is for the reporting period of 1 January2023 to 31 December 2023. In this Statement, FY23
means the financial year ended 31 December 2023, andother financial periods are referred to in a corresponding
manner.

OUR OPERATIONS

We operate under a robust governance framework of anAustralian Board, consisting of the Managing Partner,
Australia, and six partner board members, supported by theAustralian Chief Financial Officer (CFO) and Chief
Operating Officer (COO). The COO leads a professional
management team including Directors of Human
Resources, Information Technology, Business
Development & Marketing (Client Growth), Operations andFacilities, and Administration.

Locations and operations
In Australia, K&L Gates has four
offices in Melbourne, Sydney,
Brisbane and Perth.

Who We Are
K&L Gates is a fully integrated global law firm partnershipwith locations across five continents. With over 30 practicegroups within nine broad practice areas, K&L Gates iscommitted to diligent and meticulous legal work delivered in
an innovative and commercial way.

Our lawyers are able toadvise on legal matters
across all of Australia.

Notwithstanding that we are part of a global law firm,
the operations of the Reporting Entity are focused inAustralia and overseen by the Australian Board. This
has limited our exposure to modern slavery risk on ageographical basis due to the robust regulatory framework
enacted by the Australian government. This, in conjunction
with our own governance framework as well as the nature of
our workforce, has ensured that the risk of modern slavery in
our operations is relatively minor.
Our clients include leading multinational corporations, growthand middle-market companies, capital market participants,
entrepreneurs in every major industry group, public sector
entities, education institutions, philanthropic organisations
and individuals.

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OUR SUPPLY CHAINSGLOSSARY

As a professional services firm, our supply chain largely
consists of products and services which support ourdelivery of professional legal services to our clients.

For the purposes of this Statement:

Tier 1 suppliers are businesses that provide goods
and services directly to K&L Gates

An analysis of our spend data for our Australian offices,with almost 649 separate supplier entities, was conductedin conjunction with a third party technology provider. It
identified that over 99% of our direct suppliers are
Australian-based, with other suppliers based in the UnitedStates, Singapore, the United Kingdom, China, and HongKong. From our data, we were able to track the first ten
Tiers of our supply chain.

Tier 2 suppliers are businesses that provide goods
and services directly to our Tier 1 suppliers or that
contribute directly to the goods and services our Tier 1
suppliers provide to K&L Gates, and

Tier 3 suppliers are businesses that provide goods
and services directly to our Tier 2 suppliers or that
contribute directly to the goods and services our Tier 2
suppliers provide to our Tier 1 suppliers, which arethen provided to K&L Gates,

The industries in which our direct suppliers operate wereidentified as:









Hotels, clubs, restaurants and cafes

and additional tiers of suppliers have a corresponding
meaning.

Retail trade
Education services
Membership organisations
Recreational, cultural and sporting services
Printed matter and recorded media
Post and telecommunication services.

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SUPPLY CHAIN MAPPING AND
IDENTIFICATION OF MODERNSLAVERY RISKIn FY23 we engaged an independent external industry expert to provide K&L Gates with a quantitative risk assessment of themodern slavery risk in our supply chains. This assessment is weighted based on our annual spend with Tier 1 suppliers, andprovides K&L Gates with a theoretical "number of slaves in our supply chain". The results of this analysis were positive, with a fulldescription provided below.

No actual or suspected cases of modern slavery were identified over thereporting period in our operations or supply chains.
This analysis was done to create a comprehensive supply
chain that identified any potential modern slavery risks fromour direct suppliers to the tenth tier of our supply chain. The
analysis involved the interaction of a number of factors that
operate to elevate the risk of modern slavery within business
operations and supply chains, including:

Total supplier spend amounts (i.e., the value of our direct
supplier contracts)Industry category and the industries that feed into themfurther down the supply chain, and

Depth of "tiering” within the supply chain(s) (e.g., Tier 3
suppliers, Tier 5 suppliers).

The overwhelming majority of our direct suppliers are
Australian-based entities. Due to the robust regulatory
framework in Australia, these suppliers are less likely to haveoccurrences of modern slavery within their respective
operations. Nevertheless, we conducted in-depth analyses ofour direct suppliers to obtain a more holistic view of ourmodern slavery risk profile.

IN-DEPTH ANALYSIS – DIRECT SUPPLIERS
In the further analysis conducted on our suppliers, our second,
third and fourth Tier suppliers were identified as having a
potentially elevated modern slavery risk profile compared tothe otherwise low risk profile of our other suppliers in Tiers 1, 5
or other tiers.
However, additional desktop due diligence indicated that they
are also mandatory reporting entities under the Australian
and/or UK modern slavery legislation or possess robust
policies and statements relating to ethical sourcing and acommitment to positive social outcomes. This does not, of
itself, indicate the absence of modern slavery risk but rather isa positive indication to us that our suppliers are undertaking
proactive steps with regard to modern slavery.

IN-DEPTH ANALYSIS – SPECIFIC
INDUSTRIESAs previously noted, the overwhelming majority of our direct
suppliers do not present a geographic risk. However, in ourefforts to ensure the minimisation of any risk, we undertook an
identification and analysis of certain industry categories thatwere classified as potential risk areas, as geographicalanalysis alone provides limited insight into modern slavery risk.
By classifying our suppliers into specific industries andanalysing the risk of modern slavery within those industries,
K&L Gates was able to identify potential risk areas from which
we plan to take proactive steps in future due diligence.
Three key industries were:1.

Retail trade services

2.

Hotels and restaurant services.

3.

Textiles and manufactured goods.

We did not identify these industries as having an elevated risk
profile due to any specific high-risk activities being undertaken
by our direct suppliers, rather, our identification of theseindustries was largely due to the more significant proportion of
our spend over the reporting period which was attributable tosuppliers in these industries. However, the majority of theminor risk identified in our comprehensive supply chain occurs
in the more remote tiers of our supply chain, where K&L Gates
has a reduced ability to exert influence, as the risks wererelated to labour-inputs for manufactured materials.
Despite this, K&L Gates conducted further analysis to gain an
insight into the particular root causes of this increased level ofmodern slavery risk to better inform future supplier onboarding
and the scope of our future activities in the modern slavery
space.

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Retail Trade
As a professional services firm, K&L Gates sources foodand beverages from local markets, supermarkets andwholesale businesses. The items are used for client
events we host in our offices, internal meetings and forgifts. This is part of our service delivery for clients andguests who come to our offices and to provide food anddrinks for our staff, including for initiatives to encourage
and reward our staff when they work in the office post
COVID-19.
An analysis of the key suppliers within this spaceindicated their increasing focus on corporate social
responsibility initiatives in the form of wage security,
working conditions, ethical sourcing policies, suppliercodes of conduct and adherence to modern slavery
legislation and guidance, both in Australia and abroad.
Similarly, the items we purchased were often from
Australian businesses and sourced locally. There has
been a slight shift in preferences as many Australian foodand beverage brands are now considered the best in theindustry. Our staff provide feedback about their likes and
we are always keen to support local businesses.
The analysis yielded positive results in that the majority of
the risk of modern slavery occurs in the remote tiers in
K&L Gates’ comprehensive supply chain, meaning we areunlikely to have caused, or contributed to, modern
slavery through our operations and supply chains but
rather are merely linked by virtue of the raw inputs
sourced by our suppliers.

Australian Hotels Restaurants, and Cafes
This industry category represents a range of small to large
businesses that supply food and catering services to K&L
Gates. Whilst our direct suppliers are not identified ascarrying out activities that have an elevated risk of modern
slavery, they source a broad range of inputs from otherindustries and services. These include:



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


Retail trade
Wholesale trade
Paper containers
Property operator and developer services
Domestic telecommunications services.

The hospitality sector is recognised as a potential risk
area for the occurrence of forced labour and other modern
slavery practices within Australia. Migrant workers, suchas international students in hospitality, are particularly
vulnerable as evidenced by instances of exploitation thathave been widely publicised in the media. Whilst we havenot identified any specific allegations of modern slavery
connected (either directly or indirectly) with our suppliersin this industry category, we recognise it as an area for
ongoing due diligence.
The inputs for this industry also attract a risk of modern
slavery given the raw inputs include the retail andwholesale sourcing of food products from Australia andoverseas sources. The agricultural sector is an input forthis particular industry and is subject to an elevated risk ofmodern slavery due to the exploitation of migrant workers
on farms and the use of labour-hire companies, which
may be undertaking risky practices. This, combined withthe seasonal nature of agricultural work, may lead to poor
labour practices.
Considering the above, whilst K&L Gates has not
identified any instances of modern slavery occurring, we
will be using the findings to inform any future engagementwith suppliers in the area, as well as engage with current
suppliers to ensure positive practices.

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ADDRESSING MODERN SLAVERYRISKS – FURTHER DUE DILIGENCE
AND REMEDIATIONONGOING DUE DILIGENCE
The information gleaned from our second assessment, ofover 400 unique suppliers, has formed the basis ofongoing due diligence activities beyond our reporting
period. In undertaking such analysis, risk factors formodern slavery have become readily apparent and we
now capture relevant information to inform future decisionmaking based on industry and geographic factors. This
has allowed us to take a proactive approach to engaging
and onboarding new suppliers and allow us to mitigate
modern slavery within our supply chain before we engage
with the prospective supplier.

POLICIES AND AGREEMENTS
K&L Gates has a number of firm-wide policies that havebeen implemented to address social and ethical issues.
These policies have been reviewed to ensure they reflect
our commitment to addressing modern slavery in ouroperations and supply chains.
K&L Gates has developed a supplier onboarding andengagement process utilising public search tools, such as
Supply Nation, and implemented a supplier questionnaire
to query the supplier’s modern slavery risk, including
material sourcing and staffing. This has been applied inparallel with the initiatives associated with our firm's
Innovate Reconciliation Action Plan and ongoing activities
to support Indigenous and First Nations peoples.
In 2022 K&L Gates joined the Australian Legal Sector
Alliance (AusLSA), an industry-led association working
collaboratively to promote best practice sustainability
commitments and performance across the legal sector.
AusLSA's sustainability framework includes sustainable
and inclusive workplaces, community support,
environmental conservation and responsible governance.
In keeping with our holistic approach to environmental,social, and governance (ESG) and sustainability, ourmembership of AusLSA promotes greater transparency,
and additional tools and resources to law firms that assist
the implementation of programs and policies that improvetheir sustainability impact. Using a collaborative andinclusive approach facilitates the development of bestpractice sustainability frameworks, guidance and reportingfor the Australian legal sector.

These actions have allowed K&L Gates to appropriately
communicate our commitment to mitigating modern
slavery to our staff, suppliers, clients and stakeholders
generally, as well as equip key members of our firm toappropriately engage with at-risk aspects of ouroperations in a holistic way.

Grievance Mechanisms
In July 2023, K&L Gates put in place a Whistleblower
policy called the “Speak Up Policy.” The policy provides
both our current and former employees, partners andcontractors with a mechanism to anonymously reportbehaviour that is dishonest, fraudulent, illegal, unethical,
or any conduct that would be detrimental to K&L Gates,
including concerns relating to modern slavery.
In FY23, K&L Gates did not receive any reports of actualor suspected instances of modern slavery in its operations
or supply chains through any whistleblower channels.

EDUCATION AND TRAINING
As part of our ongoing Learning and Professional
Development Program, training continued.
As part of our Continued Professional Development (CPD)
education for clients and K&L Gates lawyers, twopresentations which included identifying and remediationof modern slavery risks. The topics were given on:Climate change related disclosures and accuracy of
ESG product marketing

ASIC Enforcement Trends and Priorities.

These sessions allow lawyers to gain CPD points (with1 hour of training equivalent to 1 CPD point) in which 10
points are needed each year, ending 31 March.
Internal meetings, including with partners and senior
lawyers in Australia, have also been conducted to provide
updates in relation to modern slavery, and to increaseawareness of our clients’ and our own modern slavery
footprint.
This action was undertaken to educate our lawyers andsupport staff about modern slavery as they are the groupmost likely to identify and potentially report any perceived
instances of modern slavery due to the extent of theirinvolvement in the day-to-day operations of K&L Gates.

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CONSULTATIONK&L Gates recognises the importance of engaging with its
numerous constituencies to formulate a holistic andfulsome approach to the risk of modern slavery.
In the process of drafting this Statement, K&L Gates
engaged numerous business units within the firm,
including senior lawyers of various practice areas, humanresources, corporate services, and our businessdevelopment and marketing departments in addition to ourcommittees for ESG and Sustainability, and Reconciliation
Action Plan. As part of this dialogue, requests for
information, discussion on risk factors and an agreementon the course of action for this reporting period and futurereporting periods were facilitated.
K&L Gates and its controlled entities are centrally
managed by the Board, Deputy Chief Operating Officer,
Australia and Deputy Chief Financial Officer, Australia. As
the Australian Board has members from each Australian
office, this allows us to coordinate our response andapproach to addressing modern slavery risks across ouroperations. The Australian Board meets monthly and any
issues or matters pertaining to modern slavery can be
discussed at those meetings.

In addition, every two years we undertake a global internal
engagement survey. This survey was completed by 79%
of people across the globe in May 2023. The survey
measures how enabled, engaged and energised people
are across various categories including sustainableengagement, collaboration, career, senior leadership,
immediate management and retention. The results arebroken down across demographics including
race/ethnicity, gender, LGBTQ (where consistent withlocal laws), caregiving status. From these results we areable to target policies and initiatives to improve theexperience of people in the workplace.
This extensive consultation process allowed for theidentification of modern slavery risk factors in ouroperations and supply chain and helped inform the actions
taken by K&L Gates to manage our firm-wide exposure tomodern slavery.

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MEASURING THE EFFECTIVENESSOF OUR MODERN SLAVERYRESPONSE
K&L Gates is committed to ensuring ongoing compliance and refinement in the modern slavery space. We intend to continue
to update our analysis of our comprehensive supply chain and conduct year-on-year comparative analyses in order todiscern quantitative changes in our modern slavery risk profile and assess the effectiveness of our response.
In addition, we have established a number of Key Performance Indicators (KPIs) to measure, on an ongoing basis, theeffectiveness of implemented measures for addressing modern slavery risks in our business operations and supply chains.

Key Performance Indicators

Priority Areas

These KPIs have included:

K&L Gates has identified specific priority areas for due
diligence activities in upcoming reporting periods including:

The rollout and implementation of new policies todirectly address modern slavery issues in the context
of a global law firm.

Updated and introduced new procedures for supplieronboarding to assess modern slavery risks. As per our
ethical sourcing strategy, we are updating our supplierself-assessment questionnaire to include a broader
range of risks and more concise questions that are
more directly related to our Supplier Code of Conduct.
Improved the tracking of goods and services
purchased by K&L Gates to increase transparency of
our supplier chains beyond Tier 1 suppliers.

Conducted regular reporting and tracking of new
suppliers.

Embedded a Speak Up Policy (Whistleblower Policy),
including the ongoing monitoring of the handling of any
complaints or grievances.



Firm-wide rollout of targeted modern slavery training.

Monitoring and increasing the level of supplierengagement specifically for addressing modern
slavery issues.

Product-specific modern slavery analysis. Building on
the industry-category risk analysis that has been at thecore of the modern slavery risk assessment activities
carried out during the reporting period, we intend to focus
on the specific products that form part of the ‘typical’ supply
chain for a professional services/law firm including:o paper products and other office consumableso computers, printers, servers and other electronic
items.

We also recognise that targeted supplier engagement
can form an important part of holistic modern slavery due
diligence activities, particularly in relation to going beyond
an analysis of Tier 1 suppliers. We intend to continue
carrying out comprehensive supplier questionnaires (and,where appropriate, further engagement) in conjunction
with our product-specific modern slavery analysis.

More internal training to improve awareness of wheremodern slavery can occur, how to engage with vendors
and suppliers and ways to remediate. This is also more
relevant as we improve how we track our expenditure(better categorisation and data entry) and identify
suppliers beyond Tier 1 suppliers.



Investment in Finance tools by implementing a new
global financial system using 3E which is integrated withtime recording, billing, expense and other payment andtracking systems.

Ongoing collaboration with local organisations andbusinesses with ethical supply practices and acommitment to alleviating modern slavery.

Establish a K&L Gates committee focused on modern
slavery which includes members from various
departments including Finance, Office Services(including our Risk Manager), Information Technology,
Human Resources, Marketing and Business
Development, and Client Services. These groups havethe largest responsibility to identify, engage andmonitor suppliers and vendors and must be part of theprocess to generate ideas for best practice to mitigate
any potential risks.

We are embarking on the above priority activities with the aimof further examining key product groups to identify areas ofpotential modern risk. We recognise that, whilst complete
supply chain visibility may be practically unachievable, thegoal is to identify, well beyond those products directly
supplied to us, a comprehensive dataset of every component
that forms part of a particular supply chain, and where (interms of country of origin or region) that component has comefrom.

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2024 AND BEYOND
K&L Gates remains committed to ongoing improvement in the modern slavery space.
K&L Gates is committed to ongoing action and continuing improvement within the modern slavery space and will
undertake the proposed initiatives to uphold our values in a practical and tangible manner. During 2024 and futurereporting periods, K&L Gates plans to focus on the following specific issues as part of our commitment to continually
improving our capacity for effective modern slavery risk identification and mitigation:

Update our relevant policies and agreements where needed to appropriately reflect our commitment to mitigating
modern slavery and raise awareness of the issue with our stakeholders

Implement a modern slavery policyImplement supplier self-assessment questionnaires as part of our standard onboarding process

Introduce mandatory modern slavery training for all staff across our Australian offices, and investigate publishing amodern slavery training module on our internal online learning platform, K&L Gates University
Enact additional initiatives to better improve outcomes for our suppliers and other stakeholders.

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K&L Gates is a fully integrated global law firm with lawyers located across five continents. The firm represents leading
multinational corporations, growth and middle-market companies, capital markets participants and entrepreneurs in every
major industry group as well as public sector entities, educational institutions, philanthropic organisations and individuals.
For more information about K&L Gates or its locations, practices and registrations, visit www.klgates.com.
This publication is for informational purposes and does not contain or convey legal advice. The information herein should
not be used or relied upon in regard to any particular facts or circumstances without first consulting a lawyer.
©2024 K&L Gates LLP. All Rights Reserved.

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