Modern Anti-Slavery Policy

Consilio Group

Slavery and Human Trafficking Statement for the year ending 31 December 2023

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 2023 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, legal staffing, 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, Australia, Singapore, Middle East, South Africa, Mauritius 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, Legility, a leading global legal services provider in December 2021, and most recently, the LOD and Syke Group in August 2023.

Consilio’s Operations and Supply Chains

Given the nature of our business we do not have an extensive range of suppliers and our operations in general mean that the risk of modern slavery and human trafficking taking place within our organisation and our supply chains is low. Notwithstanding this we consciously take proactive steps to, as far as possible, prevent modern slavery within our organisation.

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.

Since our last statement, we have reviewed and updated the Group’s existing whistleblowing policy to ensure it is robust enough to satisfy recent Directives.

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 General Counsel & VP of Legal Services (EMEA & International) acts as the central conduit for such reporting, however, all employees are encouraged to approach any member of the management team.

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. Mandatory ethics training for all employees was also undertaken during 2023.

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 on-boarding checks, we are planning to revise and update our supplier selection and due diligence process to include) carrying 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
• request confirmation that the supplier has appropriate measures at least as stringent as our own;
• use https://www.modernslaveryregistry.org, where key suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
• use reputable recruitment agencies or 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, DocBuster Limited, Anexsys Limited, Paralaw (UK) Limited, Inventus Solutions UK Ltd.