Modern Slavery Policy

LHi Group Ltd and its subsidiaries (“we” or “the Group”) are committed to conducting business with integrity and transparency. We maintain a zero-tolerance approach to modern slavery, human trafficking, forced labour, and servitude in all our operations and supply chains.

Modern slavery is a criminal offence and a violation of fundamental human rights. We are dedicated to upholding the UK Modern Slavery Act 2015, the UN Guiding Principles on Business and Human Rights, and other relevant international standards.

This policy applies to all individuals working for or on behalf of the Group, including employees, officers, agency workers, consultants, contractors, third-party representatives, and business partners.

We recognise that modern slavery can occur in any industry. While we assess our direct business operations as low risk due to the professional nature of our services, we remain vigilant, particularly in areas such as procurement of office supplies, IT equipment, and outsourced services.

Our Due Diligence Process Includes:

• Supplier Risk Mapping: We review suppliers by geographic location, sector risk, and supply chain tier to identify areas of heightened risk.
• Onboarding & Monitoring: All suppliers are subject to vetting, including declarations of compliance with modern slavery laws.
• Audits: For higher-risk suppliers, we may require third-party audits or certifications.
• Corrective Action: Where risks are identified, we will engage suppliers to remedy issues. Failure to address concerns may result in contract termination.
• Annual Reviews: We review risk levels across our supply chains and adapt our approach accordingly.

We expect all suppliers and clients to share our commitment. All supplier contracts now include anti-modern slavery clauses, similar to those we use in client agreements.

Supplier Clause Example:

The supplier warrants that it does not engage in or tolerate any form of modern slavery. Breach of this clause will constitute grounds for immediate contract termination.

We monitor compliance through:

• Annual supplier reviews
• Contractual warranties
• Ad-hoc compliance checks and audits

We provide all employees with training on modern slavery during onboarding and through ongoing updates.

Training includes:

• Annual refresher courses
• Role-specific training for HR, recruitment, procurement, and legal teams
• Online learning modules covering current trends, regulations, and identification of red flags

We aim to foster a culture of vigilance, ethics, and transparency throughout the organisation.

To ensure effectiveness, we regularly evaluate our policy through:

• Tracking incidents, whistleblower reports, and supplier audit results
• Annual internal reporting to the Board of Directors
• Policy reviews to assess areas for improvement and innovation

To date, no confirmed incidents of modern slavery have been identified within our operations or supply chain.

The Board of Directors has overall responsibility for this policy. Day-to-day implementation is overseen by the Legal and Compliance team, with management responsible for team-level compliance.

Breaches of this policy by employees may result in disciplinary action, up to and including dismissal. Contracts with third parties found in breach of this policy may be terminated.

All employees, contractors, and third parties are encouraged to report any concerns, confidentially and without fear of retaliation.

Reporting Options:

• Speak with a manager or the Legal & Compliance team
• Email: ContractsTeam@wearelhi.com
• Use our Whistleblowing Policy procedures
• Anonymous reporting via an external portal or helpline

We are committed to protecting whistleblowers and acting promptly on genuine concerns.

As part of our continuous improvement efforts, we are introducing additional vetting procedures, including Payslip verification and supplier accreditation checks, to strengthen our due diligence practices and reduce the risk of unethical employment practices.

We also require suppliers and clients to complete a comprehensive documentation pack during onboarding. This includes:

• A Modern Slavery Questionnaire
• A Code of Conduct

These documents allow us to better assess risk, ensure alignment with our ethical standards, and maintain an auditable record of supplier compliance.

We remain committed to continually improving our practices in line with technological advances and evolving legal standards.

This policy is shared internally via the staff handbook and externally with suppliers and clients. Our zero-tolerance stance is communicated at the start of all new business relationships and reiterated as necessary.

This policy is reviewed annually and updated to reflect changes in law, business activities, and identified risks.