Modern Slavery Act Statement

This statement is issued on behalf of Norton Rose Fulbright LLP and Norton Rose Fulbright Services (together, the Firm) in accordance with Section 54 of the Modern Slavery Act 2015. It serves as the Firm’s modern slavery and human trafficking statement for the financial year ended 31 December 2024 (Reporting Period).

The Firm's Business Principles of Quality, Unity and Integrity, underpin our culture and inform our decision making. We are committed to fostering a workplace where individuals feel valued, safe and respected. As a legal services provider, the Firm also acknowledges its duty to uphold the rule of law and to promote respect for human rights.

This statement illustrates how we apply our Business Principles in practice and underscores our continued commitment to effectively identifying, assessing and addressing the risks of forced, compulsory, trafficked and child labour within our organisation and supply chain.

We remain dedicated to partnering with suppliers who uphold human rights and share our commitment to maintaining high ethical standards.

Our Structure, Business and Supply Chains

Norton Rose Fulbright is a large, integrated legal practice with offices worldwide. Norton Rose Fulbright LLP, Norton Rose Fulbright US LLP, Norton Rose Fulbright Australia, Norton Rose Fulbright Canada LLP and Norton Rose Fulbright South Africa Inc are separate legal entities and members of Norton Rose Fulbright Verein. Norton Rose Fulbright Verein helps coordinate the activities of its members under a Swiss verein structure but does not itself engage in the practice of law or other business.

On 1 July 2025, Norton Rose Fulbright LLP and Norton Rose Fulbright Australia (including their respective branches and other controlled affiliates) will financially integrate to form a single, unified Europe, Middle East, Asia Pacific member firm (EMEAPAC). From 1 July 2025, there will be four member firms in the Norton Rose Fulbright Verein.

The Firm has offices in Amsterdam, Athens, Bangkok, Beijing, Brussels, Casablanca, Dubai, Düsseldorf, Frankfurt, Hamburg, Hong Kong, London, Luxembourg, Milan, Munich, Newcastle, Paris, Piraeus, Riyadh, Shanghai, Singapore, Tokyo and Warsaw. From 1 July 2025, our EMEAPAC member firm will also have offices in Brisbane, Canberra, Melbourne, Perth and Sydney.

Norton Rose Fulbright provides legal services to governments, corporate clients, and public sector bodies, with a strategic focus on six core industry sectors:

• Consumer Markets;
• Financial Institutions;
• Energy, Infrastructure and Resources;
• Transport;
• Technology; and
• Life Sciences and Healthcare.

The Firm's supply chain spans the following key categories:

1. Real Estate and related services: the Firm leases offices across EMEA, requiring maintenance, security, catering, cleaning and other services.
2. Professional Services: the Firm engages a variety of professional advisors and service providers including insurers, banks, accountants, auditors, translators, administrative services, marketing, legal counsel and recruitment agencies.
3. Travel: airlines, rail and taxi companies, travel agencies, hotels and other accommodation providers.
4. Technology: software and hardware retailers, consultants, maintenance companies and technology related service providers.

When engaging suppliers, the Firm incorporates its Additional Terms of Purchase for Goods and Services into relevant agreements. A central clause within these terms obliges suppliers to adhere to the Firm’s Supplier Charter, a document which reflects our commitment to ethical conduct, human rights and environmental sustainability.

The Supplier Charter outlines the Firm’s ethical standards for suppliers. It requires relevant suppliers to conduct their business activities in accordance with human rights principles as defined by the United Nations Universal Declaration of Human Rights and the core conventions of the International Labour Organisation.

In particular, the Supplier Charter mandates that suppliers “must not hold another person in slavery or servitude, employ, engage or otherwise use forced or compulsory labour, trafficked labour or child labour; nor engage in or condone the use of corporal punishments or mentally, physically or sexually abusive or inhumane treatment of workers”. Additionally, suppliers are required to comply with all relevant laws, including but not limited to those related to anti-bribery and corruption, as well as health and safety.

The Firm’s Supplier Charter and its Additional Terms of Purchase for Goods and Services are both published on the Firm’s website.

The Firm has established procedures to identify, evaluate, and monitor a range of supplier-related risks, including—but not limited to—those associated with modern slavery, financial crime, financial instability, data protection and reputational risks. Staff and management involved in the procurement process, including accounts payable staff responsible for vendor payments, receive training to recognise and address potential human rights concerns. Our governance framework ensures that any high-risk situations are escalated to internal subject matter experts for further evaluation and, where necessary, formal approval by senior management.

Policies

At Norton Rose Fulbright, we prioritise ethical conduct in all aspects of our operations. We have established a range of robust policies which guide the actions of those operating within the Firm, ensuring we uphold the highest standards of integrity. These include our Human Rights Policy, which underscores our commitment to respecting internationally recognised human rights standards. We work to ensure compliance with these policies by having effective procedures in place, relevant training, and oversight.

Human Rights

Our Human Rights Policy outlines the standards we expect from our people and our business partners. It applies across our supplier relationships and client onboarding processes, requiring proactive steps to raise awareness and ensure compliance. In line with the Human Rights Policy, we support our clients in promoting human rights through training, risk monitoring and mitigation, compliance with relevant laws and contractual commitments, and the adoption of industry best practices.

We reinforce our commitment through Business and Human Rights (BHR) training for relevant partners and staff. This includes a mandatory e-learning module that introduces our BHR framework, explains the core principles of our Human Rights Policy, and highlights its relevance to different roles and practice areas across the Firm.

The training is designed to equip our people with the knowledge and tools they need to uphold our values, identify modern slavery risks and take ownership of human rights responsibilities in their day-to-day work.

The General Counsel & Risk team leads oversight of the Human Rights Policy, providing expertise in human rights and ethical standards. Regular audits and ongoing training help embed a culture of accountability and ensure our Business Principles are consistently upheld.

Additional governance is provided by our Audit Committee, Social Impact and Sustainability Team, and Responsible Business Committee. These leadership groups play a key role in shaping our human rights strategy and monitoring our performance in this area.

We recognise that modern slavery risks are heightened in environments where discrimination is present. Our Global Practice Standards are designed to ensure our conduct always reflects our Business Principles—one of which is a zero-tolerance stance on all forms of discrimination.

Employment / Reporting

Our Ethical Reporting “Report It” Policy (Whistleblowing Policy) provides a means for partners and staff to report any behaviour that they believe may be improper under an internal policy, or under applicable regulations or professional rules. This includes issues such as maintaining a respectful workplace, anti-discrimination, modern slavery, human trafficking, forced or child labour, and broader human rights concerns. The Whistleblowing Policy aims to create a respectful environment, making it easier to talk about and deal with improper occurrences and behaviour.

The Whistleblowing Policy applies to all individuals working for Norton Rose Fulbright (whether in a permanent capacity or on a short-term basis) in any jurisdiction, including partners, avocats collaborators, employees, consultants, agency workers and contractors.

Employee Handbook

The Firm’s employee handbook is a further reference point for staff. It includes information on the Firm’s Human Rights Policy and Whistleblowing Policy. This handbook is given to all new joiners to the Firm, and forms part of the terms and conditions of employment. For employees working outside of the UK, employee handbooks may contain further information on local rules and regulations that must be complied with.

Due Diligence / Risk Assessment and Mitigation Processes

Our Clients

As a law firm operating in a highly regulated environment, we are bound by legal obligations and professional codes of conduct that require us to conduct due diligence on our clients and to maintain a clear definition of our engagement scope.

Guided by our ethical standards, we maintain a fundamental principle: we will not act for clients where doing so would be unlawful or ethically inappropriate. If concerns around illegality or misconduct arise during the course of a matter, we have well-established internal and external reporting channels, supported by subject matter experts and senior leadership.

Our Human Rights Policy reinforces this approach by requiring that, when opening new matters, we “implement processes to assess potential human rights impacts and take these into consideration.”

Our client and matter onboarding process is thorough, robust and sophisticated. Members of our dedicated General Counsel & Risk team are trained to evaluate the human rights records of clients, counterparties, and relevant jurisdictions during the due diligence and client and matter intake process. This assessment continues throughout the client relationship, with ongoing monitoring for emerging risks. Where heightened human rights concerns are identified, the General Counsel & Risk team conducts further analysis, recommends mitigation strategies for both the Firm and the client, and escalates issues to senior management when appropriate.

We also gather insights through our Partner Quarterly Return Questionnaire, which captures reflections on human rights considerations across all active matters. In addition to internal monitoring, we proactively engage with clients on human rights issues that may arise in their transactions or business practices. This includes advising on how to strengthen internal policies and procedures to align with human rights legislation and international standards.

Employment

We are committed to upholding the highest standards in the recruitment and employment of our people. In addition to ensuring compliance with the policies set out in our Employee Handbook, we take a proactive approach to ensuring ethical, lawful, and inclusive employment practices across all offices.

Key elements of our approach include:

• Compliance in Recruitment Processes: We ensure full compliance with all applicable laws during recruitment and onboarding, with particular attention to verifying individuals’ right to work in their respective jurisdictions.
• Due Diligence: Prospective employees undergo a thorough selection process, including background checks and employment references. For staff involved in key risk management functions, these checks are repeated annually.
• Merit-Based Hiring and Development: We recruit, promote, and develop talent based on merit and capability.
• Diversity and Inclusion: Our Diversity and Inclusion policy promotes a diverse workforce and inclusive culture.
• Respect in the Workplace: We are committed to maintaining a respectful and supportive work environment, as outlined in our Respect in the Workplace Policy.

All staff and partners are expected to adhere to our Global Practice Standards, Business Principles, and relevant regulatory requirements and professional codes of conduct. These expectations are outlined in our employment contracts, ensuring clear communication of our ethical and legal obligations from the outset of employment.

Our ongoing training programmes provide guidance on these standards and ensure staff have the relevant knowledge to properly carry out their roles. These commitments are reinforced by the Firm’s policies, as detailed in our Employee Handbook, which undergo regular updates to reflect legal and industry standards and best practice.

The Firm conforms to the London Living Wage for its London employees and complies with all regulatory requirements in each office in which we operate.

Pro Bono

As a law firm, we recognise that our unique skillset positions us to respond effectively to both global and local legal challenges. We encourage our people to apply these capabilities through our pro bono practice, which spans a wide array of causes and environments. This enables them to contribute meaningfully and create a positive impact where it’s most needed.

In 2025, the Firm strengthened the practice team with three more key roles: a pro bono Associate, a Paralegal, and a part time Senior Associate. This has encouraged an influx of lawyers getting involved in Pro Bono for the first time, helping them discover meaningful ways to contribute and make local impact.

The Firm continues to make leaps in its commitment to Pro Bono, with 59 of our lawyers making the England and Wales Pro Bono recognition list, for having each recorded over 25 hours of pro bono time.

This year the Firm continued its collaboration with Save the Children, contributing to a series of innovative and high-impact initiatives. Notably, we seconded an associate to the organisation for the fourth time, further strengthening our longstanding partnership. The secondment allows our lawyers to contribute their legal expertise directly to charity work, while gaining valuable insight into the legal challenges faced by international NGOs.

Effectiveness Tracking

The Firm has achieved the following KPIs since our previous report:

• completion of our BHR due diligence review of our Milan, Riyadh and Tokyo offices;
• soft rollout of “Intapp Terms” legal technology, which allows the Firm to better track and report on client engagement terms which cover human rights and modern slavery related measures; and
• addition of all of the Firm’s suppliers to our Client Matter Intake database, “Intapp”, for ongoing monitoring as part of the Firm’s vendor management project.

We shall report on our performance against the following KPIs in our FY 2025 Modern Slavery Act Statement:

• a BHR due diligence review of our Athens and Singapore offices. This will involve an analysis of the respective jurisdictional human rights risks and assessment of the suppliers to each office;
• business rollout and integration of human rights and modern slavery reporting utilising the Firm’s “Intapp Terms” product;
• joint modern slavery risk monitoring and reporting by EMEAPAC.

Targeted Focus

The Firm has a dedicated Responsible Business Committee which continues to address issues of business ethics and human rights, modern slavery and human trafficking.

The Firm’s Responsible Business Report was published on the Firm’s website in July 2024 and a new edition is due to be published in the near future.

The report considers the Firm’s progress across our responsible business framework pillars of:

• Business Conduct;
• Sustainability;
• Pro Bono;
• Diversity, Equity and Inclusion; and
• Social Impact.

We are aware that these issues are important to our clients and suppliers, and we strive to be a firm which ’walks the talk’.

The Firm remains a signatory to the United Nations Global Compact, a pact between many of the world’s largest businesses to adopt sustainable and socially responsible policies.

In May 2024, the Firm provided its first report to the United Nations on its implementation of international human rights and labour standards. The Firm’s next report is due to be submitted in July 2025.

The Firm’s Management Committee approved this statement on behalf of the members of Norton Rose Fulbright LLP on 30 June 2025.

View our 2024 Modern Slavery Act Statement
View our 2023 Modern Slavery Act Statement
View our 2022 Modern Slavery Act Statement
View our 2021 Modern Slavery Act Statement
View our 2020 Modern Slavery Act Statement
View our 2019 Modern Slavery Act Statement
View our 2018 Modern Slavery Act Statement
View our 2017 Modern Slavery Act Statement
View our 2016 Modern Slavery Act Statement