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Modern Slavery Policy

Modern Slavery Policy

Our Modern Slavery Policy has been put in place by our parent company, LHi Group and is effective from 16/01/2024 (16th January 2024).

Policy Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor, and human trafficking, all of which share the deprivation of a person’s liberty by another to exploit them for personal or commercial gain. LHi Group Ltd and its subsidiaries ("We") have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships. We are committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are also committed to ensuring transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers, and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory, or trafficked labor, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

This policy does not form part of any employee’s contract of employment, and we may amend it at any time.

Responsibility for the policy

The board of directors holds overall responsibility for ensuring that this policy complies with our legal and ethical obligations and that all those under our control adhere to it.

The Legal and Compliance team bears primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, addressing any queries about it, and auditing internal control systems and procedures to ensure they effectively counter modern slavery.

Management at all levels are accountable for ensuring that their subordinates understand and adhere to this policy and receive sufficient and regular training on it as well as on the issue of modern slavery in supply chains.

You are welcome to provide feedback on this policy and suggest improvements. Comments, suggestions, and queries are encouraged and should be directed to the Legal and Compliance team at

Compliance with the policy

You must ensure that you read, understand, and comply with this policy.

The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify the Legal and Compliance team as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

If you believe or suspect a breach of this policy has occurred or that it may occur, you must report it in accordance with our Whistleblowing Policy as soon as possible.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitute any of the various forms of modern slavery, raise it with your manager.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavorable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Legal and Compliance team immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in our Staff Handbook."

Communication and awareness of this policy

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, is included in the orientation process for all individuals who work for us, and regular training will be provided as needed.

Our zero-tolerance stance on modern slavery in our business and supply chains must be conveyed to all suppliers, contractors, and business partners at the beginning of our business relationship with them and reiterated as necessary thereafter.

Breaches of this policy

Any employee who violates this policy will face disciplinary action, which may lead to termination for misconduct or gross misconduct.

We reserve the right to terminate our relationship with any other individuals and organizations working on our behalf if they violate this policy.