Modern slavery and anti-trafficking statement

This statement is made on behalf of Penningtons Manches Cooper LLP pursuant to section 54(1) of the Modern Slavery Act 2015 for the financial year ending 31 March 2026.

Penningtons Manches Cooper LLP is a limited liability partnership registered in England and Wales (registered number OC311575). The firm operates internationally and includes the following subsidiaries: Penningtons Manches Cooper Singapore LLP and Bateson & Partners Law Firm. Further information about the firm can be found at penningtonslaw.com.

As an international law firm, we are committed to respecting human rights across all aspects of our operations and business relationships. We maintain a zero-tolerance approach to slavery, servitude, forced labour and human trafficking, and we seek to ensure that such practices do not occur within our business or supply chains.

This commitment reflects our vision to be the most human law firm. Grounded in our values of care, respect, collaboration and continuous improvement, we are focused on ensuring that all individuals connected to our business, are treated with dignity and respect.

This is closely aligned with our broader commitment to diversity, equity and inclusion (DEI), and to fostering working environments in which everyone is treated fairly and without harm. We expect these same standards to be upheld by those with whom we work, including our suppliers and partners.

We recognise that, while the risk of modern slavery occurring within our own operations is considered to be low due to the nature of our regulated professional services activities, risks may arise within our supply chain. We are committed to identifying, assessing and addressing those risks through proportionate and evolving due diligence and supplier engagement processes.

We also recognise that expectations regarding transparency and supply chain due diligence continue to develop, and we are committed to continuous improvement in our approach, including strengthening our understanding of supply chain risks and enhancing the effectiveness of our controls over time.

This statement reflects our ongoing commitment to acting with integrity, transparency and accountability in addressing modern slavery risks, consistent with our wider ambition to deliver positive impact beyond legal advice.

Our supply chain primarily consists of professional and operational services that support the delivery of our legal services. Key supplier categories include:

• professional business services (eg IT, consultancy, legal research tools)
• insurance providers
• property, facilities management and office services
• recruitment and HR services
• travel services
• marketing and events suppliers
• outsourced operational suppliers (eg cleaning, catering, security)

While the overall risk of modern slavery within our direct operations is considered to be low, we recognise that certain areas of our supply chain, particularly those involving outsourced, lower-paid or site-based services may present a higher risk of labour exploitation.

During the reporting period, we have taken steps to strengthen our visibility and oversight of our supply chain. This includes commencing the implementation of an AI-enabled procurement and due diligence platform, which will support structured supplier onboarding, risk classification, and automated compliance checks. This system will enhance our ability to identify higher-risk suppliers and improve consistency in our due diligence processes.

We recognise that our current visibility is primarily at Tier 1 supplier level. Expanding our understanding of risks beyond Tier 1 is a planned area of focus, and we intend to progress this following the implementation and embedding of our new procurement platform. This work is expected to be planned out during the latter part of FY2027 as our systems and processes mature, to start developing transparency in FY2028.

We maintain a suite of policies and frameworks that support our approach to preventing modern slavery and upholding human rights across our operations and supply chain. These include:

• modern slavery and human trafficking statement
• sustainable procurement policy (under review during FY27)
• concern reporting and speak-up policy (former whistleblowing policy – which explicitly protects individuals reporting concerns)
• recruitment due diligence standards, including right‑to‑work checks and processes designed to support ethical recruitment practices and reduce the risk of worker exploitation
• Living Wage accreditation, continuing to ensure all direct UK employees and onsite contractors are paid at least the real Living Wage.

Oversight of modern slavery risk sits within procurement, with periodic review by our executive board.

During the next reporting period, we intend to introduce a supplier code of conduct as part of our procurement framework. This will set out clear expectations for suppliers in relation to human rights, labour standards and modern slavery, in addition to environment, ethics, anti-bribery, and data and information security. This will support a more consistent and risk-based approach to supplier due diligence and engagement.

We also participate in external ESG assessment through EcoVadis, which includes consideration of labour and human rights practices, supporting our broader understanding of risks and performance in this area.

We take a proportionate, risk-based approach to due diligence across our operations and supply chain. Our current processes include:

• supplier onboarding procedures designed to capture key information regarding supplier operations and services
• verification that recruitment agencies comply with the Modern Slavery Act and support ethical recruitment practices, including appropriate checks on right‑to‑work, worker treatment and fair terms of engagement
• use of contractual terms and supplier engagement to reinforce expectations in relation to ethical conduct and labour standards

If instances of modern slavery or labour exploitation were suspected or identified, the firm would take a proportionate and responsible approach, focusing on protecting affected individuals and working with suppliers to address issues where possible.

We recognise that our current due diligence processes are primarily focused on Tier 1 suppliers. During the reporting period, we commenced the implementation of an enhanced procurement and due diligence platform, which will support a more structured and consistent approach to supplier onboarding, risk identification and ongoing monitoring.

As this system is embedded, we intend to strengthen our ability to identify higher-risk suppliers and apply more targeted due diligence measures. This will enable a more risk-based approach to supplier engagement and oversight over time.

We recognise that expectations regarding due diligence and transparency continue to evolve, and we are committed to further developing our processes to improve coverage, consistency and effectiveness in future reporting periods.

We take a risk-based approach to identifying and managing modern slavery risk within our operations and supply chain. As part of this, we have reviewed our risk assessment methodology to ensure it reflects evolving expectations and provides a clearer understanding of where risks may arise.

Current risk assessment

Our assessment indicates that the risk of modern slavery within our direct operations remains low due to the nature of our regulated legal services activities. However, we recognise that certain areas of our supply chain may present heightened risk, particularly where services involve outsourced, lower-paid or site-based work, or where supply chains extend across multiple jurisdictions. Key areas of potential increased risk include:

• outsourced facilities management services (including cleaning, catering and security)
• travel services, particularly in higher-risk geographies
• technology hardware supply chains
• event management and promotional goods

Planned improvements (2026–2027)

During the next reporting period, we plan to further develop our risk assessment framework by:

• expanding supply chain mapping through our procurement platform, with the aim of improving visibility across Tier 1 suppliers
• developing a supplier risk-scoring methodology
• integrating modern slavery risk considerations into procurement processes and decision-making, including broader ESG evaluation criteria

These enhancements will support a more structured and consistent approach to identifying, prioritising and managing modern slavery risks across our supply chain.

All employees complete mandatory modern slavery e-learning as part of their induction. This training is designed to help employees recognise potential indicators of modern slavery and understand how to respond appropriately.

Training content includes:

• identifying indicators of forced labour and exploitation
• reporting channels, both internal and external
• recognising potential supplier-related risks and red flags
• case studies and practical examples to support understanding

Additional targeted training is planned for 2026/27 as part of the procurement platform implementation and will be aimed at:

• procurement and finance teams
• facilities management colleagues
• supplier relationship owners

We recognise the importance of measuring the effectiveness of our approach to managing modern slavery risk. At present, we are developing our approach to performance monitoring, and we are focusing on establishing a set of meaningful and proportionate indicators.

Current indicators

During the reporting period, we monitored the following indicators relevant to modern slavery:

• modern slavery training completion rate: 93% of employees completed mandatory training
• whistleblowing reports: zero reports raised, zero investigations or resolutions required.

These measures support our ability to assess employee awareness, the effectiveness of training, and the use of reporting and escalation mechanisms within the firm.

Supporting ESG indicators

We also monitor broader ESG performance indicators, which include elements relevant to labour and human rights. These currently include:

• CDP climate disclosure
• EcoVadis

While these indicators are not specific measures of modern slavery risk, they support our wider understanding of environmental, social and governance performance, including aspects of labour and human rights within our operations and supply chain.

Development of future indicators (FY26-FY28)

As part of the implementation of our enhanced procurement and due diligence platform, we intend to expand and formalise our approach to performance measurement. Subject to further development and review, future indicators may include:

• proportion of suppliers subject to modern slavery due diligence processes
• identification and assessment of higher-risk suppliers
• actions taken to mitigate identified risks
• improvements in supply chain transparency, including mapping beyond Tier 1 suppliers
• outcomes of supplier engagement and, where applicable, audit activity

These indicators will support a more structured approach to monitoring the effectiveness of our controls and identifying areas for further improvement over time.

Our approach to monitoring and continuous improvement is supported by our broader management systems, including ISO 9001 certification. This provides a structured framework for process management, documentation and ongoing improvement, which underpins the development and implementation of our procurement and due diligence processes.

The firm’s approach to tackling modern slavery contributes most directly to the following UN Sustainable Development Goals:

• SDG 8: decent work and economic growth

(elimination of forced labour, modern slavery and human trafficking)

• SDG 12: responsible consumption and production (sustainable procurement and supply-chain transparency)
• SDG 16: peace, justice and strong institutions

(promoting ethical, transparent business practices)

We also recognise the broader relevance of SDG 10 (reduced inequalities), particularly in relation to individuals who may be more vulnerable to exploitation within global supply chains.

These priorities will be reflected in our developing ESG framework and supplier expectations as our approach to modern slavery risk management continues to evolve.

Since the period end in April 2026, we publicly affirmed our commitment to the United Nations Global Compact (UNGC) and its ten principles. This includes principle 4 (the elimination of forced labour) and principle 5 (the effective abolition of child labour), which align with our approach to managing modern slavery risk. Through this commitment, we recognise the importance of safeguarding individuals, particularly those who may be more vulnerable to exploitation (children, young people and vulnerable adults that engage or deal with us), and of promoting fair, safe and respectful working conditions across our operations and supply chain.

Building further on the progress outlined in this statement, we intend to:

• continue the implementation and embedding of our procurement and due diligence platform, enhancing supplier onboarding, risk identification and oversight
• further develop our approach to supplier risk assessment, including the introduction of risk-scoring methodologies and, over time, expanded visibility across Tier 1 suppliers
• introduce a supplier code of conduct, setting out clear expectations in relation to human rights, labour standards and modern slavery, in addition to environment, ethics, anti-bribery, and data and information security
• expand targeted training for colleagues in roles with greater exposure to supply chain risk, to strengthen our ability to identify and respond to potential issues
• develop and refine performance indicators to support more effective monitoring of modern slavery risks and the impact of our controls
• continue to strengthen the integration of human rights considerations within our broader ESG and governance framework
• enhance transparency in future statements, including providing more detailed insight into our approach, progress and areas for improvement

Approval and sign‑off

This statement was approved by the members of Penningtons Manches Cooper LLP on 17 September 2026, pursuant to section 54 of the Modern Slavery Act 2015.

Signed:

Helen Drayton
Chief executive, Penningtons Manches Cooper LLP

Date: 21 September 2026