www.clearygottlieb.com

Sustainable Purchasing Policy

Cleary Gottlieb Steen & Hamilton LLP (hereafter “Cleary Gottlieb” or “Firm”) is committed to the highest standards of social and environmental responsibility and ethical conduct.

This commitment stretches to all aspects of Cleary Gottlieb operations, including procurement. This Policy outlines the environmental, social, and governance (ESG) considerations that Cleary Gottlieb uses to guide its purchasing activities. It complements and/or reflects existing detailed policies, including Cleary Gottlieb’s Vendor Code of Conduct, and goes beyond internationally recognized standards to advance social and environmental sustainability.

I. Environmental Considerations for Vendors with greater than 50 employees

Vendor with greater than 50 employees shall adhere to the following practices:

  1. Pollution Controls: Develop, implement, and maintain practices that reduce and/or eliminate environmental pollutants. This includes proper hazardous substance, non-hazardous waste, and air emissions management.

The following areas are also preferred, monitored, and/or screened for when purchasing new products and/or in new or ongoing strategic vendor relationships:

  1. Climate Engagement: As outlined in its Environmental Policy, Cleary Gottlieb seeks to work with vendors who are engaged in mitigating and/or improving climate impacts relating to its business. The monitoring of greenhouse gas (GHG) emissions, setting of GHG reduction targets, and participation in regular reporting (self-produced CDP, or equivalent) are all key parts of Cleary Gottlieb’s purchasing considerations. Vendors should show willingness to work with Cleary Gottlieb on Scope 3 GHG reduction initiatives.
  2. Sustainable Traits: Business supplies or products will be screened for characteristics that demonstrate environmental benefits, such as recycled content (i.e. in paper), recyclability, use of renewable energy (i.e. vehicles, buildings, etc.), and certifications related to sustainable product traits (i.e. FSC, Energy Star).
  3. Sustainable Companies: Vendors will be screened for certification or scoring related to overall company sustainable management, such as B Corp certification, Carbon Neutral certified, Ecovadis or CDP scores.
  4. Resource Efficiency: Responsible management of business resources, as evidenced by waste reduction practices and targets, water management practices, and energy efficiencies.

II. Environmental Considerations for Vendors with fewer than 50 employees

Vendor with fewer than 50 employees shall adhere to the following practices:

  1. Hazardous Substance Management.  Implement a systematic approach to identify, manage, reduce and responsibly dispose of or recycle hazardous substances.
  2. Non Hazardous Waste Management.  Implement a systematic approach to identify, manage, reduce and responsibly dispose of or recycle non hazardous waste.
  3. Air Emissions Management.  Identify, manage, reduce and responsibly control air emissions emanating from its operations that pose a hazard to the environment.
  4. Pollution Prevention and Resource Reduction.  Minimize pollution, as well as conserve, energy, water and natural resource consumption by implementing efficiency, conservation and substitution measures.

III. Social Considerations

Vendors shall adhere to the following practices:

  1. Labor & Human Rights: Safeguard against discrimination, harassment and abuse, involuntary labor and/or human trafficking (see our Modern Slavery Act statement), underage labor (as defined by local laws), extensive or illegal working hours, unfair wages and benefits, or restrictions on the freedom of association in business dealings.
  2. Health & Safety: To the extent a Vendor employs individuals, ensure that staff work in a safe environment. This includes monitoring and having regular evaluation and corrective actions around occupational health and safety and hazard management, emergency preparedness, incident management, ergonomics, and related communications.  The following areas are also preferred, monitored, and/or screened for when purchasing new products and/or in new or ongoing strategic Vendor relationships:
  3. Diversity: Cleary Gottlieb is committed to increasing the commercial opportunities for diverse vendors.  In connection with its diversity initiatives, Cleary Gottlieb aims to  1) actively and routinely source qualified diverse vendors that can provide competitive and high quality products and services to the Firm; and 2) encourage the Firm’s major vendors that do not qualify as diverse vendors to commit to and support their own vendor diversity initiatives. Cleary Gottlieb will regularly report on spend across diverse vendors.
  4. Community Engagement: Cleary Gottlieb endeavors to work with Vendors that help foster social and economic development and contribute to the sustainability of the communities in which they operate.

IV. Governance Considerations

Vendors shall adhere to the following practices:

  1. Ethics: Enact ethical conduct and decisions at all times. This includes strict prohibition of activity related to corruption, extortion, embezzlement, insider trading, bribery, or anti-trust activities. Conflicts of interest must be disclosed, and the confidentiality of Cleary Gottlieb-related information maintained.
  2. Management Practices: Demonstrate, for example through a company statement, that Vendor is committed to high social, environmental, and ethical standards. Actions must also demonstrate this commitment, including but not limited to ensuring proper supply chain management techniques are in place to implement these high standards with their own supply chain, including but not limited to risk identification, audits and assessments, and corrective actions.

The following areas are also preferred, monitored, and/or screened for when purchasing new products and/or in new or ongoing strategic Vendor relationships:

  1. ESG Oversight: A clear commitment to ESG as an organization, as demonstrated through a leadership-sponsored commitment to sustainability. This can take the form of a transparent sustainability policy, and senior leadership accountability to monitoring ESG practices and progress.
  2. ESG Targets: The development of targets for sustainability improvements in areas such as GHG emissions, energy reduction, and diversity.
  3. ESG Transparency: Regular and transparent reporting on the progress made on company ESG targets, as well as the practices enacted to support that progress.

Cleary Gottlieb is committed to carrying out the considerations listed above across all its global offices. Vendors may be asked to provide evidence of compliance with the policy as a requirement for retaining their relationship with Cleary Gottlieb. Progress and compliance with this policy is available through annual public reporting and/or upon request.