Supplier Code of Conduct

Supplier Code of Conduct

Approved by Board of Directors
1st September 2026

1. Purpose

Legalease Ltd (trading as “Legal 500”) and its subsidiaries (“the Company”) recognises its corporate responsibility towards the people, communities and environment in which we and our suppliers operate.

As the leading provider of legal benchmarking services, the Company is committed to conducting business with integrity, independence, professionalism and respect. We are committed to delivering value to our customers, maintaining high standards of quality and confidentiality, supporting diversity and inclusion, protecting information and personal data, and continually improving the way we operate.

We expect our suppliers, contractors, consultants, professional advisers and other third parties (“Suppliers”) to share these principles and to conduct their businesses responsibly, ethically and in accordance with applicable laws and regulations.

This Supplier Code of Conduct (“Code”) establishes the minimum standards and expectations that apply to our Supplier relationships.

Suppliers are expected to communicate these principles to their employees, contractors, subcontractors and other relevant parties within their own supply chains and to take reasonable steps to ensure that comparable standards are maintained throughout their value chain.

2. Scope

This Code applies to all organisations and individuals that provide goods or services to the Company, including suppliers, contractors, consultants, professional advisers, temporary workers and other third parties.

The requirements of this Code apply in addition to, and do not replace, any contractual obligations agreed between the Company and a Supplier.

Where a contractual requirement imposes a higher standard than this Code, the contractual requirement will apply.

Suppliers are expected to comply with all applicable laws and regulations in the jurisdictions in which they operate.

3. Business Integrity and Ethical Conduct

3.1 Compliance with Laws and Regulations

Suppliers must conduct their business in accordance with all applicable laws and regulations in the countries and jurisdictions in which they operate.

Suppliers must maintain appropriate policies, procedures and controls to support compliance with applicable legal and regulatory requirements.

Suppliers must promptly notify the Company of any material regulatory investigation, enforcement action or legal matter that could reasonably affect their ability to provide goods or services to the Company or create a material legal, financial, security or reputational risk.

3.2 Anti-Bribery and Corruption

Suppliers must conduct business honestly and ethically and must comply with applicable anti-bribery and anti-corruption legislation, including the UK Bribery Act 2010 where applicable.

Suppliers must not directly or indirectly offer, promise, give, request or accept any bribe, facilitation payment, kickback or other improper financial or non-financial advantage.

Suppliers must maintain appropriate controls to prevent and detect bribery and corruption.

3.3 Competition and Anti-Trust

Suppliers must comply with applicable competition and anti-trust laws.

Suppliers must not engage in anti-competitive conduct, including unlawful price fixing, market sharing, bid rigging or other arrangements intended to restrict or distort competition.

3.4 Tax and Financial Crime

Suppliers must comply with applicable tax laws and regulations and must not knowingly participate in tax evasion or the facilitation of tax evasion.

Suppliers must maintain appropriate controls to prevent fraud, money laundering and other forms of financial crime where applicable.

3.5 Conflicts of Interest

Suppliers must avoid actual, potential or perceived conflicts of interest in their dealings with the Company.

Suppliers must promptly disclose any situation that may create a conflict between their interests and those of the Company, including circumstances involving Company employees, directors or representatives.

3.6 Gifts and Hospitality

Any gifts, hospitality or other business courtesies offered to Company employees or representatives must be reasonable, proportionate and for a legitimate business purpose.

Suppliers must not offer gifts, hospitality or other benefits that could improperly influence, or reasonably appear intended to influence, a business decision.

3.7 Accurate Records

Suppliers must maintain accurate, complete and appropriate records relating to their activities and dealings with the Company.

Records must be maintained in accordance with applicable legal and regulatory requirements and must not be falsified, concealed or deliberately misrepresented.

4. Confidentiality, Data Protection and Information Security

The Company operates in a business where confidential information, personal data, client information and intellectual property are important business assets. Suppliers are expected to apply appropriate standards of protection to all information entrusted to them.

4.1 Confidential Information

Suppliers must protect confidential and commercially sensitive information belonging to the Company, its customers, employees and other business partners.

Confidential information must:

  • only be used for legitimate business purposes;
  • only be disclosed to authorised persons with a legitimate need to know;
  • be protected against unauthorised access, disclosure, alteration or loss; and
  • be returned or securely destroyed when no longer required, subject to applicable legal or contractual requirements.

4.2 Data Protection

Suppliers must comply with applicable data protection and privacy legislation, including the UK GDPR and Data Protection Act 2018 where applicable.

Where a Supplier processes personal data on behalf of the Company, the Supplier must:

  • process personal data only in accordance with documented instructions and contractual requirements;
  • maintain appropriate technical and organisational security measures;
  • restrict access to authorised personnel;
  • ensure appropriate confidentiality obligations are in place;
  • support the Company in meeting its data protection obligations where required; and
  • promptly notify the Company of any actual or suspected personal data breach in accordance with contractual requirements and applicable law.

4.3 Information and Cyber Security

Suppliers must maintain information security controls proportionate to the nature and sensitivity of the services and information they handle.

Where appropriate, Suppliers should maintain controls covering:

  • access management;
  • authentication and privileged access;
  • endpoint and network security;
  • vulnerability and patch management;
  • data protection;
  • backup and recovery;
  • security monitoring;
  • incident response;
  • employee security awareness; and
  • secure disposal of information and equipment.

Suppliers providing technology, software, hosting or other critical services may be required to provide reasonable evidence of their information security arrangements.

4.4 Security Incidents

Suppliers must promptly notify the Company of any significant security incident, cyber attack, data breach or other event that could affect the confidentiality, integrity or availability of Company information or services.

Suppliers must cooperate with the Company in investigating and responding to such incidents.

5. Employment Practices and Human Rights

The Company expects Suppliers to maintain high standards of employee welfare, human rights and equal opportunity.

Suppliers must comply with applicable employment legislation and respect internationally recognised principles concerning human rights and fundamental labour standards.

5.1 Fair Employment

Suppliers must provide employees with clear information regarding their employment, including remuneration, working arrangements, benefits, deductions and applicable terms and conditions.

Employees must be paid accurately and on time and Suppliers must comply with applicable minimum wage and employment requirements.

5.2 Equality, Diversity and Inclusion

Suppliers must provide a workplace free from unlawful discrimination.

Suppliers must not discriminate in recruitment, employment, remuneration, training, promotion, termination or other employment decisions on the basis of characteristics protected by applicable law.

Suppliers are expected to promote an inclusive working environment in which employees are treated fairly, with dignity and respect.

5.3 Harassment and Bullying

Suppliers must not tolerate bullying, harassment, intimidation, victimisation or abusive behaviour in the workplace.

Suppliers must maintain appropriate mechanisms for employees to raise concerns and must ensure that individuals who raise concerns in good faith are protected from retaliation.

5.4 Health, Safety and Wellbeing

Suppliers must provide a safe and healthy working environment and comply with all applicable health and safety legislation.

Suppliers must identify and manage relevant workplace risks, provide appropriate training and information, and maintain suitable emergency procedures.

Suppliers are encouraged to support the physical and mental wellbeing of their employees.

5.5 Freedom of Association

Suppliers must respect employees’ lawful rights to freedom of association and collective bargaining in accordance with applicable laws.

Employees must not be subject to intimidation, discrimination or retaliation for exercising lawful employment rights.

5.6 Forced Labour and Modern Slavery

Suppliers must not use or benefit from forced, bonded, trafficked or compulsory labour.

Workers must be free to leave employment in accordance with applicable law and reasonable contractual requirements.

Suppliers must not require workers to surrender passports, identity documents, immigration documents or other personal documents as a condition of employment.

Suppliers must comply with applicable modern slavery and human trafficking legislation, including the UK Modern Slavery Act 2015 where applicable.

Suppliers are expected to take reasonable steps to identify, prevent and mitigate modern slavery and human trafficking risks within their own operations and supply chains.

5.7 Child Labour

Suppliers must not employ anyone below the applicable legal minimum working age.

Suppliers must comply with all applicable restrictions concerning young workers and must not permit children to undertake hazardous or exploitative work.

5.8 Working Hours

Suppliers must comply with applicable laws relating to working hours, rest periods, holidays and overtime.

6. Respectful Behaviour and Third-Party Conduct

Suppliers must ensure that their employees, contractors, subcontractors and representatives acting on their behalf behave professionally and respectfully when interacting with Company employees, contractors, clients, visitors and other stakeholders.

Suppliers must not tolerate:

  • bullying;
  • harassment;
  • unlawful discrimination;
  • victimisation;
  • threatening or intimidating behaviour;
  • abusive or aggressive conduct; or
  • other inappropriate behaviour.

Suppliers must cooperate fully with reasonable investigations into allegations of inappropriate conduct.

The Company reserves the right, where appropriate and subject to contractual arrangements, to require the removal from Company premises, events or activities of any Supplier representative whose conduct is inconsistent with this Code or the Company’s policies.

7. Quality and Service Standards

Suppliers must provide goods and services that meet agreed specifications, contractual requirements, service levels and quality standards.

Suppliers are expected to:

  • maintain appropriate quality management processes;
  • identify and manage operational risks;
  • promptly notify the Company of material service issues;
  • investigate significant failures or complaints; and
  • implement appropriate corrective and preventive actions.

Suppliers should support a culture of continual improvement and work collaboratively with the Company to improve service quality and customer outcomes.

8. Intellectual Property

Suppliers must respect and protect intellectual property belonging to the Company, its customers and third parties.

Suppliers must not use, reproduce, disclose or transfer intellectual property except as authorised by the Company or permitted under applicable contractual arrangements.

Suppliers must ensure that any intellectual property created or supplied as part of their services is appropriately owned, licensed or otherwise authorised for the intended use.

9. Environmental Responsibility

The Company recognises the importance of reducing environmental impacts and expects Suppliers to operate in an environmentally responsible manner.

Suppliers must comply with applicable environmental laws and regulations and are encouraged to identify opportunities to reduce their environmental impact.

Where relevant and proportionate to the nature of their operations, Suppliers should seek to:

  • reduce energy consumption and greenhouse gas emissions;
  • improve resource efficiency;
  • reduce, reuse and recycle waste;
  • minimise unnecessary packaging;
  • increase the use of recycled or recyclable materials;
  • responsibly manage water and other natural resources;
  • prevent pollution;
  • manage hazardous substances appropriately; and
  • consider environmental impacts throughout their supply chains.

Suppliers are encouraged to establish appropriate environmental objectives and improvement plans proportionate to the scale and nature of their business.

10. Responsible Supply Chain Management

Suppliers are expected to apply principles consistent with this Code throughout their own supply chains.

Where appropriate, Suppliers should conduct proportionate due diligence on subcontractors and other third parties presenting material risks relating to:

  • human rights;
  • modern slavery;
  • bribery and corruption;
  • environmental impact;
  • information security;
  • data protection;
  • health and safety; and
  • regulatory compliance.

Suppliers must notify the Company where the use of a subcontractor or other third party could materially affect the delivery, security or compliance of services provided to the Company, where required under the applicable contract.

11. Reporting Concerns and Incidents

Suppliers must promptly notify the Company of any significant incident that may affect the services provided to the Company or create a material legal, regulatory, security, health and safety, ethical or reputational risk.

This includes, but is not limited to:

  • data breaches or significant cyber incidents;
  • regulatory investigations or enforcement action;
  • fraud or suspected financial crime;
  • bribery or corruption;
  • modern slavery or human trafficking concerns;
  • serious health and safety incidents;
  • significant environmental incidents;
  • allegations of unlawful discrimination, harassment or misconduct; and
  • other material breaches of this Code.

Concerns may be reported through the Supplier’s usual Company contact or through the Company’s designated reporting or whistleblowing channels.

The Company will seek to handle reports appropriately and confidentially, subject to applicable legal and regulatory requirements.

The Company does not tolerate retaliation against any person who raises a genuine concern in good faith.

12. Non-Compliance and Corrective Action

Where actual or potential non-compliance with this Code is identified, the Company will seek to work constructively with the Supplier to understand the circumstances and, where appropriate, agree suitable remedial or corrective actions.

The Company reserves the right, subject to applicable contractual rights, to review, suspend or terminate a Supplier relationship where there are serious, material or persistent breaches of this Code or where a Supplier fails to implement agreed corrective actions.

Nothing in this Code limits any contractual, legal or other rights available to the Company.