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Epiq Anti-Slavery and Human Trafficking Statement

For the Financial Year Ending December 31, 2025

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and describes the steps taken by Epiq Systems Inc. and its subsidiaries (“Epiq” or “the Company”) to prevent modern slavery, forced labor and human trafficking in our business operations and supply chains.

This updated statement also reflects the direction of travel in UK public procurement, including Procurement Policy Note 009: Tackling Modern Slavery in Government Supply Chains (“PPN 009”) and the National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025, which came into force on 17 May 2026. While these instruments impose duties primarily on contracting authorities and public bodies, Epiq recognises that suppliers must be able to support clients in identifying, managing, evidencing and remediating modern slavery risks throughout the commercial lifecycle.

1. Introduction from the Board of Directors

Epiq is committed to upholding human rights and ethical business practices. We recognize the serious nature of modern slavery and human trafficking and are dedicated to identifying, preventing, mitigating and, where necessary, remediating risks across our operations and supply chains. We seek to apply a practical, risk-based approach that prioritises risks to people and supports continuous improvement rather than reliance on policy statements alone.

This statement is to be approved by the Board and signed by Caroline Woodman, Senior Vice President and Managing Director, following annual review by appropriate Legal, Compliance, Procurement and HR stakeholders.

2. Our Structure, Operations, and Supply Chains

Epiq is a global provider of legal services and technology, operating in 14 countries with over 5,000 employees. Our services include eDiscovery, court reporting, transcription, regulatory compliance, legal administration and technology-enabled legal support services. Our supply chains span North America, Europe, Asia and Australia and include technology vendors, professional services providers, facilities management suppliers, recruitment agencies, independent contractors and specialist service partners.

We maintain long-standing relationships with many suppliers and subcontractors. During the reporting period, and in response to strengthened public procurement expectations, we continued to improve our visibility of supply chain risk beyond Tier 1. For NHS and other public sector opportunities where modern slavery risk is assessed as medium or high, Epiq will seek to map relevant supply chains to at least Tier 3 where proportionate and practicable, and will maintain traceability records to support client assurance requirements.

3. Legal and Procurement Context

The Modern Slavery Act 2015 requires commercial organisations meeting the statutory threshold to publish an annual slavery and human trafficking statement describing the steps taken to prevent modern slavery in their own business and supply chains.

PPN 009 requires UK Government departments, executive agencies, non-departmental public bodies and NHS bodies to identify and manage modern slavery risks in government supply chains. It promotes a risk-based approach covering new procurements, existing contracts, supplier engagement, training, contract management and response to identified victims or incidents.

The National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025 require in-scope public bodies procuring goods or services for the purposes of the health service in England to assess modern slavery risk and take reasonable steps, proportionate to the assessed risk, to address and where practicable eliminate that risk. Those steps may include supplier due diligence, supply chain traceability, contractual provisions, records, monitoring, reassessment, corrective action and cooperation with investigations.

Epiq’s approach is designed to help public sector clients evidence proportionate supplier assurance and to support the implementation of any modern slavery requirements included in procurement documents, framework buying instructions or contract terms.

4. Policies in Relation to Modern Slavery

Epiq maintains policies and standards that support ethical business conduct and responsible supply chain management, including:

  • Anti-Slavery and Human Trafficking Policy;
  • Supplier Code of Conduct and Vendor Standards;
  • Employee Code of Conduct;
  • Whistleblowing and Integrity Hotline procedures;
  • Recruitment Policy prohibiting worker-paid recruitment fees;
  • Responsible Purchasing Practices; and
  • Information security, privacy, data protection and compliance policies relevant to supplier assurance.

These policies are reviewed periodically and are aligned, where relevant, with international standards including the UN Guiding Principles on Business and Human Rights, OECD Due Diligence Guidance and ILO Labour Standards. We expect suppliers, contractors and business partners to meet the same high standards and to prohibit the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, within their own operations and supply chains.

5. Risk Assessment and Management

Epiq assesses modern slavery risk using a risk-based methodology that considers geography, industry, workforce profile, commodity type, supplier location, subcontracting model and the wider context in which suppliers operate. These factors are consistent with the risk characteristics identified in PPN 009 and NHS guidance, including industry type, nature of workforce, supplier location, operating context, commodity type and business or supply chain model.

Our current assessment is that Epiq’s direct operations in legal services, technology-enabled court reporting, transcription and eDiscovery are generally lower risk than labour-intensive sectors such as agriculture, construction, garment production, manufacturing, logistics, healthcare, cleaning, catering and security. However, we recognise that “lower risk” does not mean “no risk”, and that risks may arise through indirect suppliers, facilities services, recruitment channels, technology hardware, logistics or complex public sector supply chains.

Key modern slavery risk indicators considered by Epiq include:

  • use of temporary, agency, migrant or otherwise vulnerable labour;
  • operations or sourcing from higher-risk jurisdictions;
  • subcontracting chains where visibility is limited;
  • outsourced services such as cleaning, catering, facilities, logistics and security;
  • technology hardware or electronics supply chains with known global labour risks;
  • use of labour recruiters or intermediaries; and
  • absence of effective grievance mechanisms or worker voice.

We maintain a modern slavery risk register and prioritise risks to people over reputational or financial considerations. Risk assessments are reviewed at least annually and may be updated sooner where there is a material change in supplier, geography, sector, procurement requirements

6. Due Diligence, Supplier Assurance and Contractual Controls

Epiq’s supplier due diligence and assurance activities include:

  • supplier onboarding checks proportionate to the nature and risk of the services provided;
  • contractual obligations requiring suppliers and subcontractors to comply with applicable laws and Epiq standards;
  • specific prohibitions against forced labour, compulsory labour, human trafficking, servitude and child labour;
  • requirements for suppliers to flow down equivalent obligations to their own subcontractors where relevant;
  • annual supplier self-assessments for selected suppliers;
  • risk-based requests for further information, evidence, policies, audit outcomes or corrective action plans;
  • whistleblower protections, grievance mechanisms and Integrity Hotline access; and
  • engagement with suppliers to improve practices where risks or gaps are identified.

For public sector contracts and frameworks, particularly NHS procurements and any category assessed as medium or high risk, Epiq will support client assurance requirements by providing relevant supply chain information, keeping records that enable the relevant supply chain to be traced, making records available on request where contractually required, and cooperating with reasonable investigations or assurance activity.

Where appropriate contract terms require it, Epiq will request from relevant subcontractors and supply chain participants the names and contact details necessary to support traceability and assurance. We will also seek confirmation that subcontractors have appropriate modern slavery controls in place and will require corrective actions where identified gaps are capable of remediation.

Epiq has not identified any confirmed cases of modern slavery in our operations or supply chains during the reporting period. However, we remain vigilant and recognise that absence of identified cases does not mean absence of risk.

7. Remediation and Response to Incidents

If a potential or confirmed incident of modern slavery is identified, Epiq will prioritise the safety and welfare of affected individuals and will avoid actions that could increase harm to victims or vulnerable workers. Our response will be coordinated by appropriate Legal, Compliance, HR, Procurement and operational stakeholders and may include:

  • immediate escalation through Epiq’s reporting and investigation channels;
  • fact finding and risk assessment, including engagement with the supplier where safe and appropriate;
  • protective action to prevent further harm;
  • development and monitoring of a corrective action or remediation plan;
  • cooperation with client, regulator, law enforcement or specialist support organisations where required;
  • review of contractual remedies, including suspension or termination where remediation is not effective or appropriate; and
  • lessons learned and update of risk assessments, controls and training.

Consistent with public procurement guidance, termination would normally be considered a last resort where continued engagement cannot protect affected people, remedy the issue or provide adequate assurance.

8. Training and Awareness

Epiq provides training and awareness to relevant employees and suppliers on recognising and responding to modern slavery risks. In 2024, 100% of procurement and HR staff completed targeted training, modern slavery awareness was included in onboarding for all new hires, and refresher training was delivered to frontline and executive staff.

In response to strengthened government and NHS expectations, Epiq will continue to develop role-based training for colleagues involved in procurement, supplier management, bid management, contract management, recruitment and public sector delivery. For NHS or high-risk procurements, Epiq will ensure that appropriate commercial and contract personnel complete relevant training on modern slavery risk in supply chains, including externally provided NHS or sector-specific training where available and proportionate.

Training materials are reviewed annually and tailored to role and risk exposure. Training will cover modern slavery indicators, escalation routes, supplier due diligence, PPN 009 risk characteristics, contractual requirements, supply chain mapping, remediation principles and victim-centred response.

9. Measuring Effectiveness

Epiq assesses the effectiveness of its anti-slavery measures through a combination of qualitative and quantitative indicators. These include:

  • completion rates for modern slavery and related compliance training;
  • supplier onboarding and due diligence completion rates;
  • percentage of higher-risk suppliers assessed or reassessed during the reporting period;
  • number of suppliers asked to provide enhanced modern slavery information or corrective action plans;
  • progress against supply chain mapping objectives, including Tier 2 and Tier 3 mapping where relevant;
  • number and status of modern slavery concerns, reports, investigations and remediation actions;
  • supplier compliance with contractual modern slavery obligations;
  • internal audit or supplier assessment outcomes; and
  • stakeholder, worker and supplier feedback where available.

These indicators are reviewed through appropriate governance channels to support continuous improvement. Epiq’s goals for the next reporting period include expanding supply chain mapping for relevant higher-risk public sector opportunities, improving supplier engagement, increasing the use of risk-based supplier assessments, and strengthening worker access to reporting and grievance mechanisms.

10. Further Steps

In the next reporting period, Epiq will:

  • continue mapping relevant supply chains beyond Tier 1, prioritising NHS, government and other higher-risk public sector arrangements;
  • review supplier onboarding questionnaires and contractual terms to ensure they capture PPN 009 and NHS Regulation-aligned requirements where relevant;
  • maintain responsible recruitment practices across all regions, including prohibiting worker-paid recruitment fees;
  • enhance training for procurement, commercial, bid, HR and contract management colleagues involved in higher-risk public sector supply chains;
  • review the modern slavery risk register and apply updated risk intelligence to supplier assurance activity;
  • strengthen evidence of effectiveness through clearer KPIs, audit outcomes and corrective action tracking;
  • collaborate with clients, suppliers, industry initiatives and specialist organisations to share best practice; and
  • upload this statement to the UK Modern Slavery Statement Registry where required or appropriate.

11. Approval

This statement has been prepared for review and approval by Epiq’s Board of Directors. It will be reviewed annually and updated as appropriate to reflect changes in law, guidance, procurement requirements, supply chain risk and Epiq’s business operations.

Approved by:

Caroline Woodman, Senior Vice President and Managing Director

Epiq Systems Inc. and its subsidiaries

Date: June 30, 2026