2022 Communication on Progress

DLA Piper

Published date

June 30, 2022

No. of questions

74

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

    1. Does the Board / highest governance body or most senior executive of the company:

    Optional comment

    2. Does the company have a publicly stated commitment regarding the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a commitment within 2 years

    Yes, and the commitment is focused on our own operations

    Yes, and the commitment includes our own operations and the value chain

    Yes, and the commitment includes our own operations and the value chain along with communities and society

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Please see our latest Sustainability Report for more information: https://www.dlapiper.com/en/uk/focus/sustainability-report-2021/introduction/

    3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a code of conduct within two years

    Yes, focused on employee conduct

    Yes, focused on employees and suppliers

    Yes, focused on employees, suppliers, and other business relationships

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Please see our latest Sustainability Report for more information: https://www.dlapiper.com/en/uk/focus/sustainability-report-2021/introduction/

    4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

    No one is specifically responsible for this topic

    Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)

    Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)

    Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights

    Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Please see our latest Sustainability Report for more information: https://www.dlapiper.com/en/uk/focus/sustainability-report-2021/introduction/

    5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

    No formal structure

    Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)

    Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)

    Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)

    Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    With respect to human and labour rights matters in our supply chain, our Procurement Action Committee reviews these risks regularly and has a direct reporting line to the Executive and the Board Risk Committee. For these risks in our direct operations, we're currently reviewing our existing processes to ensure they're fit for purpose.

    Prevention

    6. Does the company have a process or processes to assess risk?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    With respect to human rights and labour rights risk assessment, in 2022 we have updated our procurement process to allow the business to assess risk levels in this area more effectively. We are in the process of fully operationalising this process. Our new supplier management system, once on board later in 2022, will allow automation and greater efficiency.

    6.1. During the assessment of risk, which business relationships are reviewed?

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    Supplier assurance is conducted for all new suppliers and; existing suppliers. Departments such as Procurement, Data Privacy and Information Technology are stakeholders in the wider Supplier Assurance Framework. The processes involve four main stages: 1. Security Assurance Tiering Form completion – High level tiering assessment to determine the rating for the supplier based on types of data handled, access, storage etc. 2. Supplier Assurance Questionnaire (if applicable following Security Assurance Tiering results) – Sent to the supplier to answer questions about their security posture/controls based around ISO 27001 controls. 3. Supplier Due Diligence Questionnaire – Sent to all suppliers with more than 5 employees to answer questions about their company, insurance, accreditations and policies. Supplier with spend over £10K are also asked questions about their financials and Sustainability & ESG. 4. Supplier Segmentation – Risk/ Impact and Value Assessment is completed on all suppliers. Any risks identified are tracked and remediation plans put in place with suppliers when necessary. Risk acceptance escalation processes are in place.

    7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    With respect to human rights and labour rights due diligence, in 2022 we have updated our procurement process to allow the business to conduct due diligence more effectively. We are in the process of fully operationalising this process. Our new supplier management system, once on board later in 2022, will allow automation and greater efficiency.

    7.1. During the due diligence process, which business relationships are reviewed?

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    All suppliers must undergo a form of due diligence relevant to the spend and risk with the proposed supplier, prior to entering into a contract or purchase order for their goods or services. The most basic form of supplier due diligence is due diligence questionnaire and if required a credit report to assess the supplier's financial risk. Where necessary, Procurement and project stakeholders attend initial inspection visits to potential suppliers to assess compliance prior to a contract award. This includes obtaining information about their manufacturing, production, logistics operations, internal processes, health and safety, the overall working environment of their employees and a supplier’s activities and processes which contribute to reducing environmental impact, improving employee diversity and illustrating no exposure to modern slavery. Prior to a contract award, a meeting is arranged with a nominated reference. A range of questions are asked in relation to performance, contract management, supplier integrity, values and the proactivity of the account management team. A supplier is chosen after successfully passing our assessment. Ongoing Supplier Management is performed throughout the contract term in form of agreed governance set out within the contract. This includes structured monthly, quarterly and annual meetings with procurement and stakeholders, action trackers, agreed management information on spend and performance reporting. We proactively challenge the supplier to demonstrate performance efficiencies and in addition, provide timely updates on innovations which bring added value to the firm.

    Concerns and grievance mechanisms

    8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

    Optional comment
    In 2022, we updated our whistleblowing procedure by introducing an externally-run, independent whistleblowing service. Any DLA Piper colleague or business partner can file a written report using the web-based service, or can contact someone by telephone at any time. The service includes the option to report anonymously.

    8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

    No

    Yes

    Is the process communicated to all employees/workers in local languages?

    Is the process available to non-employees (e.g., contractors, vendors, suppliers)?

    Is the process confidential (e.g., whistleblowing process)?

    Are there processes in place to avoid retaliation?

    Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)

    Other (Please provide additional information)

    9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

    No process to enable remedy to stakeholders

    Remedy available to some stakeholders (i.e., some geographies, employees only)

    Remedy is available to all affected stakeholders

    Remedy is available to all stakeholders, and suppliers are expected to have similar policies

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Although the firm does not currently implement an official process, where cases may arise, these are reviewed and addressed on a case by case basis.

    Lessons

    10. How does the company capture lessons regarding each of the following sustainability topics?

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

    Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly

    Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    The answers above primarily relate to how we manage these risks in our supply chain. For anti-corruption, for our operations we conduct root cause analyses/investigation and change policies, processes and practices accordingly, although this is not systematic. For human rights and labour rights/decent work, for our operations we do not currently capture lessons systematically. However, we're currently reviewing the processes focusing on our operational risks in these areas.

    Executive Pay

    11. Is executive pay linked to performance on one or more of the following sustainability topics?

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    We currently offer both monetary (limited to UK employees) and non-monetary incentives for our office employees in relation to the management of climate-related issues but plan to introduce wider monetary incentives within next two years with the development of our internal carbon accounting scheme.

    Board Composition

    12. Percentage of individuals within the company’s Board / highest governance body by:

    Number/Percentage

    Not applicable (Please provide additional information)

    Total number of board members (#)

    12

    Male (%)

    75

    Female (%)

    25

    Non-binary (%)

    Not captured currently.

    Under 30 years old (%)

    0

    30-50 years old (%)

    25

    Above 50 years old (%)

    75

    From minority or vulnerable groups (%)

    25

    Executive (%)

    16

    Independent (%)

    16
    Optional comment
    N/A

    13. Do you produce sustainability reporting according to:

    DLA Piper reports to other third parties like CDP and EcoVadis.
    Optional comment
    We are continually improving our approach to reporting on our sustainability performance and in 2021, DLA Piper released its first Sustainability Report where we have begun to align to the GRI standard where possible. We also report against select indicators from the SASB and WEF standards and our reporting will continue to evolve and become more rigorous over the coming years. Other ESG reporting frameworks that we currently disclosure against include CDP and EcoVadis.

    Data Assurance

    14. Is the information disclosed in this questionnaire assured by a third-party?

    Since 2019 DLA Piper has had a limited assurance of its greenhouse gas emissions in line with the ISO 14064 standard. We have plans to assure a wider set of data beginning with our FY 21/22 report, including social metrics.
    Optional comment
    For more information, please reference our latest Sustainability Report.

  • Human Rights

    Materiality / Saliency

    1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?

    Commitment

    2. Does the company have a policy commitment in relation to the following human rights issues?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    2020

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    Our privacy policy sets out how we handle and treat personal data processed by us. Our internal privacy policy sets out the obligations of our people to ensure that that personal data is processed fairly and securely. We require our business partners to apply the same high standards to the processing of personal data and all third parties must undergo an information security and privacy assessment before we work with them. Data privacy training is mandatory for all our colleagues.

    2.1. For each human rights policy, is it:

    Aligned with international human rights standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving human rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of expression

    n/a

    Digital security / privacy

    Rights of women and/or girls

    n/a

    Access to culture

    n/a

    Rights of indigenous peoples

    n/a

    Free, prior and informed consent

    n/a

    Rights of refugees and migrants

    n/a

    Access to water and sanitation

    n/a

    Prevention

    3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing /mitigating the risks/impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Rights of women and/or girls

    n/a

    Freedom of expression

    n/a

    Rights of refugees and migrants

    n/a

    Digital security / privacy

    Rights of indigenous peoples

    n/a

    Access to culture

    n/a

    Free, prior and informed consent

    n/a

    Access to water and sanitation

    n/a

    5. Who receives training for the following human rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Rights of women and/or girls

    n/a

    Freedom of expression

    n/a

    Rights of refugees and migrants

    n/a

    Digital security / privacy

    Rights of indigenous peoples

    n/a

    Access to culture

    n/a

    Free, prior and informed consent

    n/a

    Access to water and sanitation

    n/a

    Response

    7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Rights of women and/or girls

    n/a

    Freedom of expression

    n/a

    Rights of refugees and migrants

    n/a

    Digital security / privacy

    n/a

    Rights of indigenous peoples

    n/a

    Access to culture

    n/a

    Free, prior and informed consent

    n/a

    Access to water and sanitation

    n/a

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    As a signatory to the UNGC, upholding the human rights of our people and the communities and partners we work with is integral to the way we do business. From a policy perspective, DLA Piper have integrated human rights considerations into various key policies, including our Supplier Code of Conduct which outlines the expectations we have for our suppliers and partners around issues such as human rights, child labour, health and safety, environmental sustainability and anti-bribery and corruption. These include supporting full and fair opportunity and diversity in our supply chain, and ensuring that human rights are protected in line with international principles such as the Universal Declaration of Human Rights. The policy has been updated to better align with ISO 20400 (Sustainable Procurement) principles. Since 2020, all employees with procurement responsibilities receive annual mandatory training around the Modern Slavery Act (UK and Australia) and potential human rights issues in our supply chain. The training covers warning signs to look out for when interacting with suppliers, and how to raise concerns. This training has recently been updated so that if offers more extensive and in-depth training to employees who have more procurement-focused roles.

  • Labour

    Commitment

    1. Does the company have a policy commitment in relation to the following labour rights principles?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    DLA Piper Human Rights and Modern Slavery Policy- 2022 Supplier Code of Conduct- December 2020

    Forced labour

    DLA Piper Human Rights and Modern Slavery Policy- 2022 Supplier Code of Conduct- December 2020

    Child labour

    DLA Piper Human Rights and Modern Slavery Policy- 2022 Supplier Code of Conduct- December 202

    Non-discrimination in respect of employment and occupation

    International Bullying and Harassment Policy- January 2022

    Occupational safety and health

    International Health and Safety Policy- December 2021

    Working conditions (wages, working hours)

    Supplier Code of Conduct- December 2020

    1.1. For each labour rights policy, is it:

    Aligned with international labour standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving labour rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    Our Supplier Code of Conduct covers our expectation of suppliers in these areas, and is publicly available. To outline our approach to the management of freedom of association and collective bargaining, forced labour, and child labour topics in our direct operations, we have a Human Rights & Modern Slavery policy, this is not currently publicly available. The policy is undergoing review and will be published later in 2022.

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks /impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    To sharpen our understanding of our strategic sustainability priorities and to understand whether we have any blind spots, we launched a global formal double materiality assessment in 2021. Part of this process included conducting an extensive stakeholder engagement exercise through an employee-wide survey across all our offices, 12 focus groups and a dozen in-depth interviews across the firm’s geographies and functions, representing all levels including leadership and newly qualified lawyers, operations teams and employee networks, new partners, and practice and sector leads, and external stakeholders.

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Actions in this area include: -Ensuring that any changes in relevant employment law and legislation are communicated to stakeholders; -Updating policies, procedures and handbooks to account for changes ; -Reviewing relevant training modules on the company's intranet and promoting bespoke training; -Carrying out investigations and where there are outcomes, ensuring that lessons are learned; -Perpetuating an open and inclusive workplace environment through our Values (Bold, Supportive, Collaborative and Exceptional), our People Networks and Support Groups.

    Occupational safety and health

    Working conditions (wages, working hours)

    4. Who receives training for the following labour rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    n/a

    Forced labour

    n/a

    Child labour

    n/a

    Non-discrimination in respect of employment and occupation

    Some of the ways in which we assess progress in this area include: -Hearing from our people network groups who present information and lived experiences to their colleagues on how best to treat everyone in an equal and inclusive way. -Ensuring relevant training modules are accessible on the company’s intranet and reviewed and updated -Promoting the company’s Values which are to: be supportive, collaborative, exceptional and bold and holding awards for demonstrated behavior. -By not tolerating unacceptable behaviors and instituting processes to address these and closely tracking outcomes for lessons learned.

    Occupational safety and health

    Working conditions (wages, working hours)

    n/a
    Optional comment
    Currently issues in our supply chain are reviewed on an ad hoc basis, as they may arise. However, we're in the process of operationalising a new tool that will allow us to systematically assess risks and follow up on any issues, and as part of this we will be able to set specific KPIs and track against them.

    Performance

    6. What is the percentage of employees covered under collective bargaining agreements?

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    Optional comment
    n/a

    7. What is the percentage of employees in a trade union or other workers' organization?

    Percent of employees (%)

    Unknown

    Not applicable (Please provide additional information)

    Employees in a trade union or on a worker committee (%)

    8. In the course of the reporting period, what was the percentage of women in:

    Percent of women (%)

    Unknown

    Senior leadership level position

    21

    Non-executive board

    25
    Optional comment
    The above senior leadership level position figure refers to our firm's partnership. In our next report, we plan to revise how we measure this figure so that it includes our Practice and Sector Group Heads.

    9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

    Salary ratio (%)

    Unknown

    Choose to not disclose

    Women / Men (%)

    Optional comment
    DLA Piper reports this ratio in our annual Gender and Ethnicity Pay Gap report which covers our UK firm: https://www.dlapiper.com/~/media/files/other/2022/uk-pay-gap-report-2021.pdf?la=en&hash=6BA12FD8250129F7CFE4BAE537E8613D722F5739

    10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    1

    11. In the course of the reporting period, what was the company’s incident rate?

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    0.1
    Optional comment
    In 2020/2021, our rate of recordable work related injuries was 0.07.

    Response and Reporting

    12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    n/a

    Forced labour

    n/a

    Child labour

    n/a

    Non-discrimination in respect of employment and occupation

    n/a

    Occupational safety and health

    n/a

    Working conditions (wages, working hours)

    n/a

    13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    In 2022, we updated our whistleblowing procedure by introducing an externally-run, independent whistleblowing service. Any DLA Piper colleague or business partner can file a written report using the web-based service, or can contact someone by telephone at any time. The service includes the option to report anonymously. In 2021 we carried out an assessment to measure the value of current and prospective suppliers to DLA Piper, as well as the potential risks they posed to the firm (including environmental and social risks). The results of this assessment informed our new supplier management framework (Total SRM). This is currently being rolled out to our strategic and critical suppliers. For suppliers who fall into these categories, or score highly for environmental and social risk, we put in place a Climate Action Plan or a Social Action Plan, as necessary. These plans outline the objectives and milestones our suppliers need to reach to align with own commitments and goals. We have also put in place processes for ongoing assurance, to ensure that supplier plans are evolving as needed. Our Total SRM meetings cover ESG matters and progress against the plans. Our new Procurement Assurance Committee monitors any key risks identified by the Total SRM, as well as regularly reviewing supplier policies to ensure they remain fit for purpose. Later in 2022, we will implement a new supplier management system to ensure ESG risk considerations are more seamlessly embedded in our procurement process. The system will enable us to gather more data about our supplier relationships, and manage ESG risks more effectively.

  • Environment

    Commitment

    1. Does the company have a formal policy on the following environmental topics?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Climate Action

    Environmental Sustainability Policy- December 2021

    Water

    Environmental Sustainability Policy- December 2021

    Oceans

    n/a

    Forests / Biodiversity / Land Use

    Air Pollution

    n/a

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Environmental Sustainability Policy- December 2021

    Energy & Resource Use

    Energy Management Policy- September 2021

    1.1. For each environmental policy, is it:

    Aligned with international environmental standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving environmental expertise from inside and outside the company?

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    Water and wastes are not material environmental impacts for DLA Piper, but are monitored individually as part of our optimisation and resource efficiency programme.

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks/ impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    [‎30/‎06/‎2022 17:04] Natalya Lozovaya: We are part of the Taskforce for Nature-related Financial Disclosures (TNFD) Forum, a consultative grouping of institutional supporters who share the vision and mission of the TNFD and make themselves available to contribute to the work and mission of the Taskforce.

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    We are looking to develop mechanisms for measuring positive impacts of our legal services eg similar to such approaches as Scope 4 ("advised emissions").

    4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

    Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)

    Climate Action

    Committed to a 50% reduction in our scope 1,2 and 3 GHG emissions by 2030 from a 2019 baseline (Absolute intensity and approved by the Science Based Targets initiative).

    Energy & Resource Use

    Target to have 100% renewable electricity by 2030 Internationally.

    Water

    100% sites monitor and report water use by end of 2023.

    Forests / Biodiversity / Land Use

    No monitoring of progress

    Air Pollution

    No monitoring of progress

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Target in place to divert at least 95% of waste away from landfill by 2025- we are currently on track to achieving this.

    Oceans

    No monitoring of progress

    4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

    Progress is reviewed against goals annually or more frequently

    Progress is reported internally to the most senior level

    Progress is reported externally

    Other (Please provide additional information)

    Climate Action

    Energy & Resource Use

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Oceans

    5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Climate Action

    Water

    Oceans

    n/a

    Forests / Biodiversity / Land Use

    n/a

    Air Pollution

    n/a

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Climate Action

    6. What were the company’s gross global greenhouse gas emissions for the reporting period?

    Scope 1 Emissions

    Emissions (tCO2e)

    1623

    Scope 2 Emissions

    Emissions (tCO2e)

    2617

    Scope 3 Emissions

    Emissions (tCO2e)

    85127
    Optional comment
    Please refer to page 112 of DLA Piper's Sustainability Report.

    6.1. Which Scope 3 categories are included in the organization’s scope 3 emissions calculation?

    7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

    Percent of revenue (%)

    Optional comment
    We are currently reviewing and testing opportunities in providing low-carbon services to our clients, read more in our forthcoming Sustainability Report.

    8. Has the organization acted to support climate change adaptation and resilience?

    Energy / Resource Use

    9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

    % of total energy consumption

    61

    Technology

    10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

    Percent of total revenue (%)

    Optional comment
    We are not currently measuring this but plan to do so in the near future.

    Sector-specific Questions

    11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.

    Optional comment
    We have selected the Financial Services option in order to submit the questionnaire as there was no option for Legal or Professional Services sector.

    Sector-specific: Water

    12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

    Water withdrawal (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    n/a

    Groundwater:

    n/a

    Surface water:

    n/a

    Rainwater:

    n/a

    Wastewater:

    n/a

    Percentage of water withdrawn in regions with high or extremely high water stress (%)

    n/a

    Water consumption (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    n/a

    Groundwater:

    n/a

    Surface water:

    n/a

    Rainwater:

    n/a

    Wastewater:

    n/a

    Percentage of water consumed in regions with high or extremely high water stress (%)

    n/a

    13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

    Water intensity of products (cubic meter/$):

    n/a

    Sector-specific: Forest, biodiversity, and land use

    14. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).

    Number

    Unknown

    Not applicable (Please provide additional information)

    Sites

    n/a

    Hectares

    n/a

    15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?

    Conversion of natural resources (hectares)

    n/a

    16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?

    No

    No, but we plan to in the next 2 years

    Yes

    Forest ecosystem restoration

    Other ecosystem restoration

    Reforestation

    Natural regeneration

    Agroforestry

    Set-aside land

    Biodiversity offsetting

    Other (please specify in text box)

    Sector-specific: Air pollution

    17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.

    Emissions (tCO2e)

    Unknown

    Not applicable (Please provide additional information)

    NOx

    n/a

    SOx

    n/a

    Volatile Organic Compounds (VOC)

    n/a

    Hazardous air pollutants (HAP)

    n/a

    Particulate matter (PM10)

    n/a

    Persistent organic pollutants (POP)

    n/a

    Other (please specify in text box)

    n/a

    Sector-specific: Waste

    18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.

    Waste Generated (t)

    498

    19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.

    Hazardous Waste Ratio (%)

    n/a

    20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.

    Single-use plastics (tonnes)

    Overall Environment

    21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

    For more information on our carbon reduction commitments, please reference DLA Piper's latest Sustainability Report.

  • Anti-corruption

    Commitment

    1. Does the company have an anti-corruption compliance programme?

    This programme was last reviewed in 2022.
    Optional comment
    DLA Piper have a detailed Anti bribery and corruption procedure which forms part of the firm's wider Ethics Policy and demonstrates our commitment to upholding the firm's standards and values. The ABC Procedure is based on internationally accepted best practice guideline.

    2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

    Optional comment
    Conflicts of interest are dealt with through the firm's Conflict Policy and Procedure. Additionally, we deal with conflicts and insider trading risks arising from traded investments in our Share Dealing Policy and Procedure.

    Prevention

    3. Who receives training on anti-corruption and integrity?

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

    Optional comment
    Beginning in summer 2022, all employees are required to go through an annual refresher training.

    4. Does the company monitor its anti-corruption compliance programme?

    Optional comment
    DLA Piper's updated procedure for tracking gifts & hospitality spending includes automatic tracking of thresholds. 

    Response and Reporting

    5. Please report the company's total number and nature of incidents of corruption during the reporting year.

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    n/a

    Confirmed during the current year, and related to this year

    n/a

    6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

    7. Does your company engage in Collective Action against corruption?

    The firm address collective action through some of our memberships like UNHCR, campaigning for ‘clean business’, our partnership with the Law Society and other sector regulators. We also engage in collective action through various pro bono projects: • We have a close collaboration with Transparency International and have co written a number of publications on facilitation payments and best practices generally, • We regularly speak at TI events and other thought leadership events on issues which include collective action against corruption. • We regularly advise companies on measures as to how they can improve compliance and how to benchmark their policies procedures and processes with industry best practices • We have a compliance Benchmarking group involving DLA Piper and clients informally discussing compliance best practices and how to interact with governments to improve both private and public sector best practices • A DLA Piper lawyer acts as Deputy Chair of the UK Fraud Advisory Panel and is a member of the UK Anti Corruption Forum - both organisations include public & private sector representatives to champion anti fraud and anti corruption measures, including collective action.

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

    Relaunch of anti-bribery and corruption process, review of policy and procedure, new technology to manage gifts & hospitality, launching new training to raise awareness.