Modern Anti-Slavery Statement

Consilio Group

Slavery and Human Trafficking Statement for the year ending 31 December 2021

Introduction

The UK Modern Slavery Act 2015 (the “Act”) requires businesses to state the actions they have taken during the financial year to ensure modern slavery is not taking place in its operations and supply chains.

Pursuant to section 54(1) of the Act, this statement refers to the financial year ending 31 December 2021 and sets out the steps taken by Consilio, LLC and its subsidiaries and affiliated companies to prevent modern slavery and human trafficking within its organisation1.

Our Commitment

We are a global provider of electronic discovery, document review, risk management and legal consulting services to law firms and corporate clients. Our supply chain includes a network of a relatively small number of suppliers in the main countries in which we operate e.g. England, Germany, Belgium, India, China, Hong Kong, Japan and the United States.

In light of our business and the services we provide, we believe there is a low risk that modern slavery and human trafficking will impact our business. Nevertheless, we are committed to ensuring that there is no modern slavery or human trafficking in our any part of our business, including our supply chain. To that end, our Modern Anti- Slavery Policy reflects that commitment to act with integrity in our business relationships and to implementing systems and controls to ensure, to the fullest extent practicable, that our suppliers will adhere to these same standards to ensure that modern slavery and human trafficking is not taking place anywhere in our supply chain.

Business Structure

A multinational, service-based company, Consilio, LLC, provides a follow-the-sun service experience of electronic discovery and related legal services. Delivering global reach and regional expertise across the world through its 1700 employees worldwide, Consilio is able to offer complete and bespoke enterprise legal services and flexible legal talent solutions offerings to its clients.

Consilio has seen rapid growth over the past few years following a number of global acquisitions, including the Xact Data Discovery Group (including Anexsys and Paralaw) in May 2021 and most recently Legility, a leading global legal services provider in December 2021.

Proactive steps to prevent modern slavery

Starting with our own business operations and service providers and then increasing the visibility we have of our global supply chains, we work to identify actual or potential risks of modern slavery and help ensure remediation where cases are identified.

Our board and senior management give close consideration to identifying potential areas of risk in our supply chain, to mitigate the risk of modern slavery and human trafficking occurring, and to protect whistle-blowers who raise concerns in this area. We are proactively identifying and implementing steps that can be taken to ensure that we are open and transparent in the way we operate our businesses, thus ensuring that our transactions and relationships are firmly compliant with our responsibilities under the Act. We intend to continue to take steps to ensure our suppliers are aware that we promote the requirements of the Modern Slavery Act 2015 and encourage them to support our principals as set forth in this statement.

These steps can be summarised into three areas: policies and procedures, risk assessment and due diligence.

Policies and Procedures

The Group currently has in place its own policies and procedures on key matters such as anti-bribery and corruption, health and safety, whistleblowing and importantly, modern anti-slavery. The Group periodically reviews its polices to ensure they are maintained to the highest standard and are reflective of current legislation and market practices. This also ensures a unified Group approach is taken to such key matters. The policies are recognised as being an important tool for documenting how to conduct ourselves as a business and individually in such a way which is appropriate, transparent and respectful of others.

In particular, the modern anti-slavery policy reflects a Group wide commitment to acting ethically and with integrity in all of our business relationships. This includes implementing and enforcing effective systems and controls in order to encourage a “speak up” culture and to minimise the risk of slavery and human trafficking taking place anywhere in our business or supply chains.

One key exercise that the Group proposes to undertake in the next financial year is a review of the Group’s existing whistleblowing policy to ensure it is robust enough to cater for the December 2021 implementation of the EU Whistleblowing Directive and the far reaching impact it will have on the Group due to its global footprint. The Group is proactively looking at ways to ensure that the policy is sufficiently future proofed to not only cater for the new EU Directive but also any inevitable updates to the current UK whistleblowing regime.

The Group recognises that, in order for its policies and procedures on all key areas to be effective, there needs to be an easily accessible reporting channel to ensure that employees are able to raise concerns about malpractice or wrongdoing in confidence, including in respect of slavery and human trafficking. Currently our Global General Counsel acts as the central conduit for such reporting, however, it is recognised that this could benefit from a more robust process and this will be considered during 2022. Whilst not currently mandatory, the EU Directive is expected to mandate the use of reporting channels within member states and recognising this early on is key to the Group ensuring compliance.

Training of employees in the key areas such as modern slavery, bribery and ethics and business conduct remains a priority for the Group and so is the ability for employees to have ready access to other educational and awareness materials. This is particularly the case for those individuals involved in the appointment of key suppliers who will have mandatory training on these key areas during the second half of 2022.

The majority of the organisations we deal with are law firms, large corporates, government and financial institutions who generally have strict pre and post contract processes and procedures in order to identify and assess potential risk areas in our supply chains, mitigate the risk of slavery and human trafficking occurring in our supply chains and monitoring such risk areas.

Risk Assessment

We assess and monitor the potential human rights risks of our business and our supply chains by considering the origin of our suppliers and by understanding and monitoring their approach to modern slavery. We endeavour to keep abreast of emerging risks through regular and transparent relations with our suppliers and, in particular, maintaining strong relationships with our labour force.

Whilst regularly encouraging legal compliance, adherence to policies and procedures and recruitment and reward practices, we are considering ways in which we can, amongst other things, identify and eliminate forced or compulsory labour in our workforce. The Group executive team meets regularly to consider the key risks to the whole group globally, and this includes monitoring modern slavery risk e.g. where new territories are entered into. The committee has a strong focus on risk management across the Group and, whilst modern slavery is considered a low risk for the business, any concerns or risks regarding modern slavery would be discussed and dealt with the utmost priority. Where necessary, measures are discussed and implemented to eradicate any such risks to the extent possible.

Due Diligence and Future steps to prevent modern slavery in our supply chains

We understand that risks of modern slavery are dynamic and can change quickly.

In addition to our usual “know your customer” checks, we will also (planned for from end of 2023) carry out the following modern slavery specific checks when onboarding new key suppliers and/or reviewing our existing key suppliers:

  • provide our suppliers with copies of our modern anti-slavery policy at the time of onboarding; or
  • require evidence of our suppliers’ modern slavery policies and review them to establish each supplier’s commitment to monitoring and reducing the risk of slavery and human trafficking occurring within their supply chains;
  • use https://www.modernslaveryregistry.org, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
  • use approved recruitment agencies or accredited umbrella companies when recruiting temporary labour for internal and operational requirements.

We will continue to maintain transparent partnerships with our suppliers to ensure they are regularly considering the impact of the Act on their organisations. Where appropriate, we will also continue to look at streamlining the number of suppliers across the Group to mitigate any risk associated with having multiple suppliers and to engender greater partnerships so as to align our values more closely.

We will continue to monitor the modern slavery risk by way of policy, risk assessment, training and due diligence and will seek to measure the effectiveness of steps taken to minimise such risk on a regular basis through management audits and communications with our supply chains.

In addition to the more general training previously identified for existing employees, the Group proposes to put in place processes such that when new hires are inducted into the Group they are provided with access to the same training materials as existing employees from the outset and are also provided with all key policies, including anti-slavery and human trafficking. This will ensure that not only existing employees but also new hires have an early understanding of the Group’s core ethics and values and the importance that the Group places on the need to have a clear understanding of its approach to key matters but, in particular, the risk of modern slavery and human trafficking.

We will continue to encourage an open and transparent “speak up” culture across the Group that ensures that all employees, at any level, feel able to openly and confidentially address any concerns they may have regarding modern slavery, human trafficking or indeed any other key issues in the knowledge that matters will be taken seriously and without retaliation.

This statement was approved by the board of Consilio, LLC.

Signed

Andrew MacDonald, Authorised Representative, Consilio, LLC
Michael Flanagan, Authorised Representative, Consilio, LLC

 

1 This statement has been prepared on a Group basis but specifically covers the following entities within the Group: Consilio Global (UK) Limited, Consilio Europe (BR009169), DocBuster Limited, Anexsys Holding Company Limited, Anexsys Limited, Paralaw (UK) Limited, Inventus Solutions UK Ltd.