31 October 2025

This statement is made in accordance with section 54 of the Modern Slavery Act 2015 (the Act) and sets out the steps taken in our last financial year (1 May 2024 – 30 April 2025) throughout our global business to identify and reduce the risk of modern slavery occurring within either our business or supply chains.

1. Overview of our business and supply chains

Freshfields is a global law firm, operating as a limited liability partnership registered in England and Wales (with registered number OC334789) and authorised and regulated by the Solicitors Regulation Authority (SRA no. 484861), with branches and related undertakings across the world. This statement is published on behalf of Freshfields globally.

In autumn 2024, we announced a significant brand refresh to better reflect the firm and its ambitions for the future. The refresh included a new wordmark and the shortening of the firm’s legal name from Freshfields Bruckhaus Deringer to Freshfields.

Freshfields has around 5,700 partners and active staff across Continental Europe, the UK, Asia, the US, and in the Middle East and North Africa. We comply with all applicable employment legislation relating to employee terms and conditions, including pay and the freedom for employees to terminate their employment at any time.  All UK employees earn at least the “Real Living Wage” set by the Living Wage Foundation. 

Our larger areas of spend with suppliers (including contractors) are premises, technology, human resources and facilities.  Freshfields’ spend is centred in the UK, Germany and the US. Our global and first-tier suppliers are primarily contracted from the UK, which is also the primary location of our procurement team – with smaller local supplier agreements being managed at the level of each office.  Our spend, by value, in the last financial year was highly concentrated with large suppliers providing us with technology, professional services and facilities services.

2. Risk assessment

In previous years, the firm’s modern slavery advisory group (see section 4. below) oversaw an initial “heat mapping” exercise – taking into account factors including jurisdiction, category of spend and length of supply chain – and the identification of specific areas in which it would oversee further, detailed due diligence in relation to modern slavery in our supply chains.  These areas were in the following categories:

1. On-site personnel, including office cleaning and catering and hospitality staff (not directly employed);
2. Off-site personnel (not directly employed); and
3. Products procurement.

As part of this exercise the advisory group identified on-site contracted services as an area of particular focus. The modern slavery advisory group has in the last year confirmed that these areas remain the salient risks for our business.  Our approach to addressing this heightened risk is addressed below.

3. Our approach to combatting modern slavery

Freshfields is committed to combatting modern slavery in all its forms.  This is an explicit priority within the firm’s Responsible Business programme which forms a key element of the firm’s wider strategy. We expect the same high standards of those we work with (see further details below).  More generally, our commitment to responsible business, observing the highest ethical standards and acting with integrity is embodied in the firm’s values.¹   

We have been a supporter of the United Nations Global Compact since 2009, and, within our sphere of influence and in our role as professional advisors, are committed to supporting and enacting values in the areas of human rights, labour standards, the environment and anti-corruption.  These are key features of our Responsible Business approach. 

As an international business with global supply chains, we adopt the international law definitions of forced labour² and human trafficking³ to frame our response to modern slavery as part of our Responsible Business programme and in fulfilling our responsibilities under the Act.  Relevant national criminal offences are addressed by us accordingly.

In addition to this high-level commitment, we have several operational policies relevant to our approach to this issue and these are subject to continuous review and development.  They are published on the firm’s intranet which is available to all employees. 

• This year, we have published a new Supplier Code of Conduct that clearly sets our expectations of our Suppliers with regard to ESG matters, including focus on modern slavery. This has been deployed on our externally facing website and has replaced our previous Responsible Business Procurement Guidelines and Operating Principles.
• We have an internal policy on Human Trafficking and Modern Slavery which applies globally to all partners, employees, officers, consultants, contractors, volunteers, interns, casual workers, agency workers and others providing services to our firm from time to time.
• Our Global Policy in Relation to Reporting Claims, Complaints and Other Issues, Raising Concerns and Whistleblowing covers reporting obligations and protection of whistle blowers. It also encourages anyone who suspects wrongdoing to report it as soon as possible, in the knowledge that concerns will be dealt with confidentially, taken seriously and investigated as appropriate.  In addition, we have local policies in Austria, Belgium, France, Germany, Italy, the Netherlands, and Spain, in accordance with local laws relating to whistleblowing.
• As alternative channels for raising concerns, we have the Freshfields global Speak Up Hotline (run by an independent service provider) and, in addition in Germany, a separate Ethics Committee Hotline.  The Speak Up Hotline is also available to contractors, suppliers and other third parties.
• We also have the following internal policies to ensure we observe the highest personal, ethical and professional standards in everything we do and operate with integrity and respect at all times:
• Being Freshfields values (setting out the behaviour we can expect of each other, and should expect of ourselves, across all levels of the firm and in all locations in which we operate)¹;
• Global Policy against Bullying, Harassment and Other Unacceptable Behaviour;
• Equal Opportunities policies¹; and
• Global Procurement Policy.

We continue to implement our Responsible Procurement Strategy, including those elements related specifically to modern slavery.

• We have developed a structured approach to the management of suppliers via a supplier management framework. This framework is designed to enable improved transparency and collaboration with our suppliers. It allows Freshfields to readily target and assess Modern Slavery risks with our key global and UK suppliers, with regard to the risk assessment outlined above. To further support this approach, we have  been partnering with EcoVadis since December 2023, an external sustainability ratings platform, to help in our assessment of the sustainability performance of our strategic suppliers, including assessment of their human rights commitments. Furthermore, our internal supplier due diligence questionnaire, which forms part of our supplier onboarding process, includes questions related to Modern Slavery.
• We continue to extend the scope of our assessment of modern slavery risk across our supply chain. This has included the assessment of a further 2,100+ suppliers in Germany since the adoption of the German Supply Chain Act (LkSG).  In this regard, our Germany supply chain has been analysed and categorised into High, Medium and Low risk categories⁴ and further assessments are being done for the High and Medium risk suppliers.

• Additionally, we continue to ask our suppliers to commit to our Supplier Code which addresses modern slavery (95% of the suppliers who responded via the Global Procurement team’s supplier onboarding tool have confirmed adherence to our Supplier Code). We are now introducing a further assessment related to those suppliers who do not confirm their acceptance. This assessment will determine whether the services provided are related to those higher risk categories identified in “2. Risk assessment” of this Statement – appropriate action will then be taken on a case-by-case basis. In addition, we have expanded our risk assessment methodology to include US suppliers.

• The firm’s standard contract terms have provisions relating specifically to modern slavery.  These terms are mandated in new contracts over a minimum value and as an addendum to longer running existing contracts on renewal. In addition, our purchase order terms and conditions include an obligation for our suppliers to comply with the Supplier Code and all applicable anti-slavery and human trafficking laws, statues and regulations from time to time in force and not engage in any activity that would constitute an offence under the Modern Slavery Act 2015.  

We continue to operate our modern slavery advisory group (more details in section 4. below), which provides input on the structured approach to suppliers discussed above. Further, as part of our client sustainability practice, our lawyers assist our clients in respecting international human rights and complying with applicable legal obligations, while also advising on a range of related operational issues, including modern slavery compliance programmes, as detailed at: Human rights and supply chain | Freshfields   

4. Due diligence processes

Our efforts in relation to modern slavery are supported by an expert advisory group which is chaired by a partner who specialises in Global Business and Human Rights.  The advisory group is comprised of representatives from the following business functions:

• Procurement;
• Risk and professional ethics;
• Internal Audit;
• Responsible Business; and
• Global Business & Human Rights.

The purpose of the advisory group is to provide expert guidance and advice (including in relation to best practice) to the firm’s leadership (centrally, and across functions) in relation to modern slavery issues.  In the last year, members of the advisory group have continued to have discussions with the firm’s senior leadership regarding the management of modern slavery risk.  In addition, our Internal Audit function specifically considers modern slavery in its global internal audit reviews (particularly in the context of reviewing procurement and supplier contracts), with regard to the risk assessment outlined above, and with particular focus on higher-risk areas.  As well as identifying opportunities to improve the firm’s controls that inhibit instances of modern slavery in its supply chain, these internal audits have had a subsidiary aim of ensuring increased awareness of modern slavery and its risks across the firm’s network of offices. 

Our standard request for proposal (“RFP”) template includes two specific due diligence questions on modern slavery, has been in place for over four years and ensures sustainability (including modern slavery) is a core consideration of supplier selection. Furthermore, our Global Procurement team’s supplier due diligence process covers those of our suppliers who provide global services to all the Freshfields offices as well as those suppliers providing services specifically to our larger offices in the UK and Germany and the US. This process includes Modern Slavery elements, and suppliers are also asked to confirm adherence to our Supplier Code.

We will continue to monitor our modern slavery due diligence processes on an ongoing basis and identify opportunities to strengthen the prevention of modern slavery within our business, particularly as our operations and the context in which we operate evolves and new risks for modern slavery potentially emerge.

5. Measuring effectiveness

As noted above, 95% of suppliers responding via the Global Procurement team’s supplier onboarding tool have confirmed their adherence to our Supplier Code. In the context of our office internal audits, recommendations in respect of modern slavery have been provided to several of our global offices in relation to contractual best practice for on-site contracted business services, which have been accepted and acted upon.

Our global offices continue to take opportunities to integrate Responsible Business (including modern slavery) considerations in local purchasing decisions in higher risk areas:  last year our London office tendered for new catering services and selected a provider specifically committed to our Responsible Business ambitions. Our ongoing local office moves will continue to have Responsible Business commitments as a key consideration in the selection of new suppliers.

We have not in the last year received any modern slavery-related complaints through our whistleblowing channels or our Speaking Up or Ethics hotlines.

6. Training

Human trafficking and modern slavery is now part of our annual mandatory training to the firm across all of our offices.

In addition to the firm’s mandatory training, and its policies set out in section 3. above, the firm maintains global business and human rights and modern slavery toolkits that are designed to provide our lawyers with the practical resources that they need to advise our clients on human rights and modern slavery issues. 

We have continued to provide information and training on modern slavery issues to our clients, in conference format, in individual sessions and through our Sustainability blog. 

As a UN Global Compact member company, we took part in the first edition of the UN Global Compact ‘Sustainable Suppliers Training Programme’. We have invited over 600 of the Firm’s suppliers to take part in a training session on the Ten Principles of the UN Global Compact and Sustainable Development Goals.

7. Collaboration and leadership

We are members of the UN Global Compact UK Network’s working group on modern slavery.

Through our pro bono practice we continue to act directly for victims of human trafficking, and for charities working to combat human trafficking.  This year, for example, we concluded a case for an individual in the UK who had been enslaved and exploited for 26 years. During this time, he was subjected to repeated assaults, violent threats and forced labour. Nevertheless, his application to the UK’s Criminal Injuries Compensation Authority had been refused outright. We appealed, preparing a 2,000-page bundle of witness evidence and legal submissions, as well as neurologist, care and psychologist expert reports. The tribunal awarded our client over £350,000, the highest amount ever awarded to a survivor of human trafficking under this compensation scheme.  More about this case is available here: https://www.freshfields.com/en/about-us/case-studies/significant-modern-slavery-compensation-award. More about our pro bono work in this area is available here: freshfields.com/en/about-us/case-studies/human-trafficking/.

Approvals

This statement was authorised and approved on 3 November 2025 by the Senior Partner on behalf of the Freshfields global partnership.

 

Georgia Dawson
Senior Partner

Signatories

This statement has been signed by representatives of Freshfields worldwide to reflect the firm’s commitment to global working and our responsible business strategy.

Georgia Dawson

(Senior Partner, Freshfields LLP)

Mark Higgs

(London COO; Director, Freshfields Services Company)

Sarah Solum

(US Regional Managing Partner, Freshfields US LLP)

 

Matthew O’Callaghan

(Asia Regional Managing Partner, Freshfields)

Rick van Aerssen

(Managing Partner, Freshfields Rechtsanwälte PartG mbB and Freshfields PartG mbB)

¹ As is also reflected in the firm’s global Freshfields Code which was launched in July 2024 and refreshed in 2025.
² Article 2, International Labour Organisation Forced Labour Convention 1930; Article 1, Abolition of Forced Labour Convention, 1957.
³  Article 3, Protocol to Prevent, Suppress and Punish Trafficking in Persons, Supplementing the United Nations Convention Against Transnational Organized Crime (Palermo, 2000).
⁴ Pursuant to the LkSG, these risk categorisations relate to human rights risk overall, and not exclusively modern slavery risks.