Cooley (UK) LLP Modern Slavery and Human Trafficking Statement

This statement is published in accordance with Section 54(1) of the Modern Slavery Act 2015.

Our business

Cooley (UK) LLP (Cooley UK, we, our) is a limited liability partnership registered in England and Wales. Cooley is an international legal practice with offices across the United States (through Cooley LLP) and with affiliated practices in other jurisdictions, including England and Wales through Cooley UK (together, Cooley practices). The Cooley practices are separate legal entities which have been established under, and operate in compliance with, applicable local laws and work together to function as an integrated international law firm.

Cooley focuses on technology, life sciences, venture capital and fund formation, but it has experience in a wide array of practice areas, along with having a litigation and disputes practice. We have zero tolerance for modern slavery and are committed to taking all legally required steps to prevent it from happening anywhere in our business or supply chain.

Our services

As a professional services organisation, we consider the risk of modern slavery within our business to be very low. As a result, we do not maintain separate policies in relation to those matters; however, we do provide training to our staff that are involved in procurement. We have a Concerns at Work Policy published on our intranet which enables any member of the firm to report known or suspected breaches of ethical or legal standards – including slavery, human trafficking, and forced or child labour – without fear of retaliation, allowing the firm to take any necessary corrective action.

Our supply chain

In relation to the provision of professional services, our ‘supply chain’ is straightforward and mainly consists of other regulated professional services – banks, intermediaries, accountancy practitioners, other law firms, barristers, expert witnesses, etc. As such, we believe the risk is low with respect to issues of trafficking and modern slavery, and we do not at this stage take or propose to take any specific action in connection with our supply chain. We may revisit this position if our experience or perception of the risk changes.

We consider the supply of internal (nonprofessional) services and goods – being for the most part not professionally regulated and/or sourced from countries with less well-developed legal protections against exploitation – may carry a marginally greater risk of slavery or human trafficking than the supply of professional services. These services include catering, office cleaning, security and maintenance, photocopying, transport, and hotel and travel booking. At no point before the date this statement was published have we had any reason to suspect the existence of exploitative practices (slavery, child labour or trafficking) in our supply chain.

Nonprofessional supplier requirements

The conditions for being an approved supplier will apply to the renewal of existing contracts and to new supply relationships we enter into after the date of this statement. Each Cooley UK supplier receives a Vendor Code of Conduct that sets out key values that we expect from our vendors, suppliers, their subcontractors, parties and agents (collectively, suppliers). The Vendor Code of Conduct requires that suppliers have appropriate policies and practices that apply to their employees and supply chain. Consistent with applicable law, suppliers will, at a minimum, ensure that they:

  • Comply with all applicable laws and regulations regarding human rights and labour standards.
  • Are not complicit in or tolerate human rights abuses, including, but not limited to, any form of forced labour, slavery, human trafficking or child labour.
  • If applicable, comply with requirements of the UK Modern Slavery Act 2015.
  • Not discriminate or harass any worker on the basis of any protected characteristic, including but not limited to, race, color, religion, creed, gender and gender identity, age, disability, sexual orientation, ancestry, national origin, or any other basis prohibited by law.
  • Provide a safe, healthy and respectful work environment for all workers, with adequate facilities, equipment, training and protection.
  • Respect the freedom of association and collective bargaining of workers, and not interfere with or retaliate against any worker who exercises these rights.
  • Pay workers fairly and timely, in accordance with applicable laws and regulations, and provide them with clear and accurate information about their wages and benefits.

Suppliers operating in regions or engaging in business practices with elevated risks of modern slavery are subjected to more in-depth due diligence.

Corporate responsibility

Responsibility for Cooley UK’s compliance with the Modern Slavery Act lies with the London office’s Co-Partners in Charge and the Compliance Officer for Legal Practice. They will keep under review the steps taken to comply with the Modern Slavery Act and will make any necessary changes to the policies and procedures of Cooley UK as they deem fit.

Updated March 2025