9th August 2021

To our stakeholders:

I am pleased to confirm that CMS reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

Sincerely yours,

Dr Matthias Lichtblau
Executive Director, CMS Legal Services EEIG

CMS – all firms

In line with the UN Guiding Principles, CMS respects and supports fundamental human rights and we work to guard against complicity in human rights abuses.
We strive to avoid causing or contributing to adverse human rights impacts on our people and, through the running of our offices, on those who work for us through our supply chain. We also commit to addressing such impacts immediately should they occur.
Women and gender equality and the rights of other groupings such as the disabled and LGBTQ+ is a key focus for us at CMS. To this end, our Diversity & Inclusion Charter was signed off by our Executive Committee in July 2021. It states that: “As an international organisation with clients and employees spanning a multitude of countries, and cultures, we believe that diversity is of fundamental importance to CMS. Engaging and supporting a diverse and inclusive workforce that reflects the diversity of our clients and their sectors is the basis for a sustainable and successful business.
“This charter serves as a framework to help firmly embed these beliefs across our organisation and foster a diverse workforce and an inclusive workplace for all at CMS. All members of the CMS Executive Committee (and the firms they represent) as well as the CMS Executive Team have endorsed this charter and are committed to fostering diversity and practising inclusion within CMS.”

UK, CEE, China, Middle East
We have a Modern Slavery Statement and Ethical Procurement policy. As part of our commitment to respecting and supporting fundamental human rights we provide pro bono legal support to a range of charities and organisations that promote human rights and work to eradicate human rights abuses. For example, we advise the Happy Child International Foundation, which carries out campaign, research and advocacy work in order to end Child Sexual Exploitation and Abuse (CSEA), and Rights of Women, a charity working to eradicate violence against women.

Our diversity & inclusion (D&I) strategy, Future Facing Inclusion, is a way of thinking and being. It brings together everyone at CMS as well as our clients and communities, whatever their backgrounds, to develop thriving careers, positive cultures and new ways of working. It is a force for change.
D&I is championed at the senior level across the firm and externally to ensure that CMS drives change not only for its people and communities, but also for the legal sector and the wider business community.

Our strategy is articulated around three pillars:
• A culture of Trust, Respect and Inclusion: educating, empowering and building accountability across the whole organisation
• Processes & Practices: reviewing all our processes and practices using the Employee Life Cycle as our framework
• Collaboration: engaging on the topic, raising awareness, sharing knowledge, experiences and best practice internally across locations and through our employee-led networks and in working with regulators, government bodies, clients and suppliers. We also collaborate with a number of charities/NGOs and external organisations to deliver our vision.

Examples of our D&I strategy in practice include:
• Employee Networks: open to all, our Employee Networks help push the diversity agenda forward, providing a platform to raise awareness and discussing relevant issues. Although they each focus on a different aspect of diversity, they also work together to address intersectionality and drive change.
• Times Top 50 employer for Women: - for the 6th year in a row we have been recognised as a Times Top 50 employer for Women.
• Social Mobility: we are involved in a range of social mobility initiatives with the aim of widening access to the legal and business world. These include developing legal apprenticeships, participating in PRIME and the Social Mobility Business Partnership and now in its 10th year, the CMS Law Scholarship, which helps disadvantaged young people to enter the legal profession.

Germany
The Supplier Code of Conduct explains CMS Germany’s expectations with regard to environmentally and socially responsible corporate governance. Knowing the Code is a basic requirement for supplying goods or providing services for CMS Germany. We therefore expect our suppliers to observe the principles contained in the Code and to act accordingly. CMS Germany launched the CMS Foundation in 2015 with a specific funding approach. With its mission statement "Access to justice. For all." it is committed to ensuring that everyone can rely on our legal system - regardless of origin, social and family status, educational background or financial means. Access to justice is a fundamental human right and the foundation for a self-determined life. Since its establishment, the Foundation has provided financial support to more than 50 non-profit organisations and law clinics. In 2020, it also created the pro bono programme CMSengage! in which employees of CMS Germany provide voluntary legal advice to non-profit organisations. The CMS Foundation has been intermediary between lawyers and non-profit organisations for more than 50 pro bono mandates so far.

Both the financial support and the pro bono mediation focus on organisations that look after vulnerable people living in difficult social or economic conditions. It is often more difficult for them to get their rights. The CMS Foundation is particularly committed to them, including poor and under-served people, refugees, victims of violence and human trafficking.

Gender equality and women's rights play a major role in the foundation's activities. A large proportion of the foundation's funding is directed at organisations that fight against sexual and domestic violence. More than 80% of those affected are women and girls. The pandemic has also led to a steep increase in violence against women and girls, thus reinforcing inequalities across every sphere - from health and the economy, to security and social protection. In addition, the CMS Foundation has provided pro bono mandates to numerous organisations working to improve human rights, such as the Society for Freedom Rights (freiheitsrechte.org), who fights for fundamental and human rights through strategic litigation, the German Institut für Human Rights (www.institut-fuer-menschenrechte.de), the independent national human rights institution of Germany, open democracy (www.opendemocracy.net), an independent global media organisation seeking to encourage democratic debate across the world through reporting and analysis of social and political issues. In terms of its contribution to the United Nations 2030 Agenda, the CMS Foundation contributes in particular to Sustainable Development Goals 5 (Gender Equality), 10 (Reduced Inequalities) and 16 (Promote just, peaceful and inclusive societies).

At CMS Germany, diversity stands for variety and a culture of mutual appreciation.
We see dealing with people of different nationalities, genders, ethnic and religious origins, sexual orientations and with a wide range of experiences as a matter of course and an obligation. Indeed for us this diversity translates into a long-term business advantage. Our client base mirrors a variety of firms acting not only locally but also internationally. As an international law firm, we take into account the cultural and social environment to ensure we give our clients the best legal advice. Employees from different countries, backgrounds and with individual expertise and a wide range of experiences contribute to the success of our clients as well as to our success as a firm.

Therefore we actively promote exchange through specific internal and external expert groups, secondments and networks. For example, we are a member of Nushu (Home | Nushu (teamnushu.de)), a business network for women that brings together academics from various industries and professions for active exchange. As a cooperation partner of the Women into Leadership initiative (iwil.eu)), we contribute to the sustainable development of female leaders.
In addition, the firm supports the Proud@Work (Start - Proud at Work) with pro bono legal services, which promotes equal opportunities and working for a diverse workplace free of discrimination and homophobia.

As a premium Supporter of the LGBTIQ+ Career Network for Lawyers:ALICE (ALICE | Das LGBTIQ+ Karrierenetzwerk für Jurist:innen), CMS has been advocating for a respectful and diverse corporate culture since 2020.

CMS Germany signed the Diversity Charter (Charta der Vielfalt - Für Diversity in der Arbeitswelt (charta-der-vielfalt.de) in 2012. With this, we document our everyday efforts to innovatively, openly and creatively build and maintain an appreciative and people-friendly working environment.
Full commitment on the job, support in organising at home - Balancing work and family life is still a challenge for most people. Many questions are raised – the most urgent is probably the care of children or nursing care for close relatives. With our social partner, famPLUS, we offer our professionals individual support in the areas of childcare, care and the household.

Austria and CEE
We take diversity very seriously and uphold this in all 11 of our jurisdictions by supporting:
• women – via pro bono work, mentoring programmes and a variety of projects and support mechanisms, e.g. counselling women who are housed in women’s shelters because of domestic violence
• cultural and religious diversity.

Netherlands
As an international organisation with customers and employees spanning a multitude of countries, cultures and professions, D&I are of fundamental importance to CMS. Our commitment to promoting D&I is broad, encompassing the following:
• developing and supporting a diverse workplace in which all are welcome regardless of gender, marital status, race, colour, national or ethnic origin, social or economic background, disability, religious belief, sexual orientation or age
• creating an environment that encourages new ways of thinking and working and values the contributions and perspectives of all – especially those with experience, ideas and work styles different from our own
• supporting all staff with a broad range of policies, practices and procedures which recognise individual contribution and performance, develop each individual’s capability and give everyone an equal opportunity to use their talent and fulfil their potential
• providing a workplace free from discrimination, harassment and bullying, where everyone is treated with dignity and respect.

CMS Netherlands has signed the following :
• The Talent to the Top Charter: a public commitment and code with agreements regarding the realisation of gender diversity at top and sub-top management levels
• EQUAL in LEGAL statement: this initiative of General Counsel Netherlands promotes and stimulates diversity and inclusion in the corporate legal industry. On the EQUAL in LEGAL Platform we share knowledge and initiatives related to D&I.

France
Strengthened by the humanist values inherited from the firm’s founders, CMS Francis Lefebvre Avocats is committed to promoting inclusion in the broadest sense:
• a policy that engages in the community to develop the norm and accords with public policies
• a human resources policy concerned with inclusion:
o training and team building
o strong actions in favour of gender parity with mentoring and training programmes
o work/life balance
o a pro bono commitment for employees with a focus on education and inclusion.

CMS’s Diversity & Inclusion Charter, approved in July 2021, sets the following goals:

• work towards achieving 30% women on Boards
• aim for equal gender representation (50:50) when selecting the heads of international PAG and Sector groups
• provide training to promote D&I across CMS including unconscious bias training
• offer equal career opportunities and manage talent recruitment through processes that embrace D&I
• foster CMS-wide support networks (women, LGBTQ+, disabilities, race and ethnicity, religion or belief)
• contribute to communities and social causes through employee volunteering and pro bono work.

These will be assessed in time for our second Communication on Progress in 2022.

CMS – all firms

As a law firm, upholding the highest professional standards and complying with all laws, regulations and rules relevant to our business is an absolute priority. Our responsible business and social impact strategy aims to improve the impact of our business on society and the economies of the regions within which our offices are based.

We expect the same high standards from those we work with and are committed to ensuring that there is no modern slavery, human trafficking or child labour in our supply chains or in any part of our business.

UK, CEE, China, Middle East
We have a Modern Slavery Statement and Ethical Procurement policy in place which reinforces our commitment to ensuring the highest standards of behaviour in our suppliers, particularly in relation to labour and other forms of human rights.
We are dedicated to maintaining a fair, ethical and inclusive workplace for all our staff. We comply with all applicable employment legislation relating to recruitment, including right to work evidence. We have clear Whistleblowing, Grievances and Dignity at Work policies which are published on our intranet site; if there are any concerns about wrongdoing or breaches of law, these can be raised in confidence without fear of disciplinary action.
Through our Social Impact programme we are working to eliminate discrimination in the wider communities we operate in. We have created a Social Impact Fund which empowers our people to support community projects across the world that contribute to the UN Global Sustainable Development Goals. In particular we are focusing on Reducing Inequalities and Access to Justice and eliminating discrimination in these areas. In 2021 the Social Impact Fund will support over 70 organisations across the world.
We also provide pro bono support to a range of charities and organisations that work to eliminate discrimination. For example, CMS has been the Official Pro Bono Legal Sponsor of Pride in London since 2012, and has been sponsoring and walking in many more Prides – both in the UK and in Europe – since 2017.

Germany
With over 600 lawyers and tax advisors, CMS is one of the leading law firms in Germany in the field of business law. CMS bears social responsibility not only by providing legal advice, but also beyond that. CMS lawyers and employees are already committed to the common good in many ways at all locations. With the establishment of the CMS Foundation by CMS Germany, the firm is adding an important component to its social commitment. ( https://www.cms-stiftung.de/die-stiftung/ ). Our pro bono programme plays a vital role in this field. Several hundred activities per year combine our expertise in a number of legal areas with the demand from social entrepreneurs and societies as well as from non-profit organisations.

Austria and CEE
We have started a certification process for socially responsible employers based on the international standard ISO 26000 SOCIAL RESPONSIBILITY in Slovenia.

• We will continue to implement our labour policies across all our operations.
• We will continue to review and reinforce how we monitor labour risks across our supply chain.
• We will continue to strive to be as diverse and inclusive as possible.
• We will continue to support social impact and pro bono initiatives that focus on eliminating discrimination.

CMS – all firms

As a global law firm, we are part of the service sector and as such are not involved in activities that directly impact the environment to the same degree as for example manufacturing or the travel industry. However, we clearly recognise that in providing our global legal and tax services, our day-to-day operations have an impact on the environment. We are committed to reducing these adverse impacts and, where we can, to have a positive impact on the environment.

UK, CEE, China, Middle East
We have an Environmental Policy which sets out our commitments including to:
• operate compliantly, achieving or exceeding all compliance obligations in our operations
• create realistic objectives and targets in environment management to reduce our impacts, including science-based targets
• effectively control the environmental aspects and impacts arising from our activities
• educate and inform our personnel on environmental challenges, this policy and the actions they can take
• challenge our suppliers and contractors to innovate in support of our commitment
• identify and implement technologies and techniques as appropriate that will reduce our impact
• reduce and sustainably manage the waste that we produce
• assess the risks and opportunities in environment management for our operations and manage them accordingly
• consider the long-term impacts of our services in decision-making
• review and report on our progress.

Our climate commitments include:
• Board commitment: sustainability is a central, strategic priority for the firm at Board level. Our Sustainability Committee, led by our Executive Director, meets regularly to prioritise and oversee implementation of our climate change and sustainability commitments
• net zero by 2025: we have led the legal sector in the UK by setting science-based targets for carbon reduction, aligning ourselves with the UN Goals for Sustainable Development and committing to an ambitious goal of net zero by 2025. A number of other firms within CMS are looking to adopt this approach
• science-based targets: CMS UK was the first of only two law firms globally to announce and set science-based targets to measure its carbon reduction progress. Our targets have been independently verified by the Science Based Targets Initiative (SBTi). A number of other firms within CMS are looking to adopt this approach
• CDP measurement: the UK firm is ranked by CDP, the highly respected not-for-profit which measures how organisations are reporting and managing their impacts on the environment. We score an impressive “A-” for both our own activity and for our work with our supply chain
• pro bono legal support: we provide pro bono legal support to a range of environmental charities and organisations. For example we partner with The Chancery Lane Project, a collaborative platform to develop new model clauses and contracts to address climate change.

Germany
Our climate commitments include:
• Board commitment: sustainability is a key strategic priority for the company at the Board level. Our Corporate Responsibility Board, led by our Corporate Responsibility Director, meets regularly to set priorities and oversee the implementation of our corporate responsibility goals on climate change and sustainability
• CDP measurement: CMS Germany is assessed by KlimAktiv GmbH, a non-profit company for the promotion of climate protection. KlimAktiv supports the determination, evaluation and reduction of our carbon footprint. (https://www.klimaktiv.de/de/212/ueber-uns.html )
• DGNB certification: DGNB System for Buildings is a transformation and management tool that supports building operators, owners and users in the development of a sustainable and climate action-oriented real estate strategy. By systematically considering all relevant information about the building and its characteristics, the usage situation and the real consumption data, the system helps to create transparency and identify optimisation potential. This minimises risks and increases investment security. We are striving for DGNB certification of all our buildings. Currently, our office building in Cologne is being certified as part of a pilot project. In Germany buildings cause 30 percent of the greenhouse gas emissions so building operations pose a vast potential to achieve our climate action goals. This requires a targeted, holistic, yet building-specific approach.

Austria and CEE
CMS RRH recently became the first law firm in Austria to be certified as an ÖKOPROFIT company by ÖkoBusiness Vienna. Companies participating in the programme must prove through an environmental report that appropriate improvements have been implemented and that new measures are already planned for the following years.
With the Environmental Report 2020 and the ÖKOPROFIT award, CMS was certified, among other things, for:
• improved waste management thanks to an extensive recycling programme
• use of sustainable and reusable raw materials
• increase in the share of organic and Fairtrade products
• significant CO2 savings thanks to the “job ticket” (an annual public transport pass) for employees.
The focal points and goals for 2021 and 2022 are:
• further reductions of energy consumption in office activities and in the area of indoor climate
• renewed reduction in office requirement and the amount of waste
• expansion of the use of video and telephone conferences to reduce our business travel carbon footprint after COVID-19
• continued promotion of sustainable mobility within Vienna.
We have introduced an environmental policy and targets for Vienna and CEE.

Latin America
In this region, there is a prolific growth in environmental laws – and their implementation is not always easy. To help companies be compliant with the latest regulations, at CMS we provide innovative tech such as “George”, a software-based solution that identifies in real time the regulations that come into force and provides each company with a database regarding the applicability of these regulations. This tool, developed over 15 years ago by CMS Peru in partnership with a third party, is being used in several markets in Latin America and is hugely appreciated by clients from very different industries who struggle with the implementation of the latest environmental regulations.

We have also advised Insolar, a not-for-profit association, on various corporate and regulatory matters including the drafting of a consortium agreement relating to its projects to install rooftop solar distributed generation in underprivileged Brazilian communities.

France
Avoiding, reducing and offsetting our environmental footprint is a major challenge for our firm. We have put in place an ambitious environmental responsibility policy involving all of our expertise and mobilising all of our staff.

Our environmental approach is organised around very specific areas such as recycling, digital technology, our building, our purchases, the fight against waste and soft mobility.

In addition, we have chosen to encourage two major causes in our pro bono strategy through donations and other actions:
• equal opportunities and inclusion – sponsoring skills in tax, legal and social matters
• the environment – projects to offset our carbon footprint.

Finally, as legal specialists, we support our clients in all their ecological transition issues. Environmental issues have become increasingly important over the last 30 years. Yet the signing of the Paris Agreements in 2015 marked a break with the past. It has reflected a shift in thinking in favour of a global ecological transition, taking into account global issues and the needs of future generations.

Such issues as reinvention of the energy model, development of renewable energy sources, transformation of industrial tools, massive renovation plans for service sector buildings, development of the circular economy, the rise of green finance of ecological taxation and the switch from all-oil transport to clean mobility are huge issues for our clients. Our firm, a player in this transition, has recognised multidisciplinary expertise enabling it to understand the issues and to serve the objectives pursued by its clients in this demanding context.
 

All CMS firms

Every CMS firm has an obligation to adhere to ethical and professional standards of behaviour according to global and local rules. Each of the CMS member firms are bound by their own local lawyers’ bar ethical regulations and code of conduct. This commitment derives from the CMS membership agreement and the client code of conduct. Sustainability has this year been added to our due diligence procedure for new CMS offices and also for new suppliers. The Compliance Officers and the Data Protection Officers of all CMS member firms meet regularly in calls to discuss standards, issues and programmes to continuously improve standards across CMS.

Risk and Compliance are key areas of the CMS global strategy. Focus areas are:
• client service
• professional standards and ethics
• conflict check
• data protection
• compliance with anti-money laundering regulation.

We are working on a global “Know Your Customer” policy with the aim to launch in the next 12 months. At a local level, firms have their own policies and procedures for money laundering/know your customer, identifying sources of funds and client due diligence. However, we are sharing best practices and supporting our local offices with software tools and external databases to identify ultimate owners, private individuals and sanctions.

In all our firms, procedures are in line with the standards which are set by the local bar association or in the respective penal codes:
• CMS UK and its subsidiaries in Central and Eastern Europe follow the UK Bribery Act (UKBA)
• In France, the Spain II Law is modelled on the UKBA and the Foreign Corrupt Practices Act (FCPA)
• In Switzerland, Germany, Chile, Russia and Belgium, the existing local rules are in line with the principles of the FCPA or UKBA although the acts are not directly applied
• OECD recommendations are followed in yet other of the 42 countries where CMS is present.

All CMS firms

We have robust policies and procedures on client and matter onboarding, anti-money laundering and bribery and corruption which we review regularly. Our people are encouraged to raise concerns quickly and confidentially and we provide regular training on these subjects.
We advise our clients on all aspects of risk, regulation and governance, and as part of our commitment to working against corruption in all its forms, we provide pro bono legal support to a range of charities and organisations that work in this area.

We continue to keep all our risk and anti-corruption processes and policies under constant review and will enhance it where appropriate.

Germany
We have set up our Compliance Office to deal with these issues. The Compliance Office is responsible for compliance with regulatory requirements associated with the practice of law. This also includes AML and anti-corruption measures where CMS acts in line with the standards which are set by the local bar association or set in the relevant penal codes or other laws, supported by policies and procedures.