This episode brings together our CC&I and ESG teams to consider supply chain risks, both in the context of failure to prevent fraud and of broader sustainability issues. Elizabeth Head, Kate Meakin and Rebecca Chin discuss whether suppliers are associated persons for the purposes of failure to prevent fraud, increased international expectations and requirements around human rights and environmental due diligence on supply chains, and the steps that companies can consider taking to address these risks.

Further information on the topics covered in this episode can be found in these links:

• A summary of failure to prevent fraud is here https://marketing.hsf.com/20/33497/landing-pages/des0003152-v1.pdf

• Further information on ESG and money laundering issues in supply chains is here https://www.herbertsmithfreehills.com/notes/fsrandcorpcrime/2024-posts/court-of-appeal-decision-shines-a-spotlight-on-esg-and-money-laundering-issues-in-supply-chains

• Information on the EU forced labour ban is here https://www.herbertsmithfreehills.com/insights/2025-01/eu-council-adopts-ban-on-products-made-with-forced-labour

• Information on the Corporate Sustainability Due Diligence Directive is here https://www.herbertsmithfreehills.com/insights/2024-03/corporate-sustainability-due-diligence-to-become-mandatory-across-the-eu

• We discuss UK calls for the introduction of mandatory human rights due diligence here https://www.herbertsmithfreehills.com/insights/2025-01/uk-house-of-lords-select-committee-calls-for-the-introduction-of-mandatory-human-rights-due-diligence

• We discuss the EU's Omnibus proposals here https://www.herbertsmithfreehills.com/notes/esg/2025-posts/The-EU-Omnibus-Package-%E2%80%93-What-do-we-know-so-far-

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