U.K. Modern Slavery Act Transparency Statement

Our Firm

Gibson, Dunn & Crutcher LLP (“Gibson Dunn” or the “Firm”) is a leading international law firm with more than 1,300 lawyers and 20 offices in major commercial centers across the globe, including London.  The Firm practices in the United Kingdom through a limited liability partnership (Gibson, Dunn & Crutcher UK LLP) registered in Delaware that is authorized and regulated by the Solicitors Regulation Authority.  The Firm practices in the United States and certain other jurisdictions through a limited liability partnership also registered in Delaware.

The UK Modern Slavery Act

The Modern Slavery Act 2015 (the “Modern Slavery Act”) is a United Kingdom law focused on the prevention and prosecution of all forms of “modern slavery,” including human trafficking and forced or compulsory labor.  Section 54 of the Act requires certain business organizations to prepare and publish a statement regarding the steps they have taken during the preceding financial year to ensure that modern slavery is not taking place in any part of their business or supply chains.

Financial Year Ending December 31, 2017

Slavery and human trafficking are serious human rights offenses that Gibson Dunn strongly condemns in all of their forms.  During our last financial year, leaders of Gibson Dunn’s London office and Firm lawyers with relevant expertise in the field of supply chain transparency have continued to consider the risks of slavery and human trafficking taking place in any part of the Firm’s business or supply chains.  In light of the nature of our business as a professional services firm and our supply chains—which are generally comprised of office space/equipment and technology, facilities, transportation, recruitment, and financial services—we believe the risks of slavery and human trafficking taking place in any part of the Firm’s business or supply chains are relatively low.  The Firm is nonetheless committed to taking steps—including those summarized below—to prevent such conduct from occurring anywhere in its business or supply chains.

  • Policies and Procedures:  We maintain various policies and procedures relevant to slavery and human trafficking, including policies requiring compliance with applicable laws and ethical conduct by Firm lawyers and staff.  Those policies have been the subject of further consideration this year from their specific application to the work of the Firm’s London Office.
  • Procurement Controls:  Gibson Dunn takes care to seek appropriate assurances, primarily through purchasing or services agreements, that the third parties with which the Firm contracts for goods and services are complying with all applicable laws, including the Modern Slavery Act.  Our Global Procurement Team engages in procurement reviews with our major suppliers, during which such assurances are sought, confirmed, and introduced into purchasing and service agreements wherever possible.  Such reviews were conducted, in the ordinary course, in 2016, and the Firm will continue to focus on obtaining such assurances in the future.
  • We have secured the inclusion in agreements with certain major suppliers of provisions affording us with the right to on-site inspections and audits of the suppliers’ facilities, including those with staff engaged in providing services to us working in jurisdictions with elevated risk of modern slavery.
  • We have, in the last year, required members of the Firm’s Global Procurement team to review and sign off on the Firm’s current ethical conduct related policies.

Approval

This statement has been authorised and approved by Thomas M. Budd, a partner in the Firm’s London office, on behalf of the partners of Gibson Dunn’s limited liability partnerships.

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Thomas M. Budd

June 30, 2018