Modern Slavery & Human Trafficking Policy

Introduction

LCC Support Services acknowledges the Modern Slavery Act 2015 and this statement sets out LCC’s actions to understand all potential modern slavery risks related to its business and to put in place
steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and supply chains.

There are an estimated 20.9 million people trapped in some form of slavery today which is referred to as Modern Day Slavery or Human Trafficking.

Modern Day Slavery/Human Trafficking is recruitment, transportation, transfer, harbouring or receipt of persons by improper means (such as fore, abduction, fraud or coercion) for an improper purpose including forced, bonded or child labour and sexual exploitation.

Organisational Structure and Supply Chains

The business offers direct cleaning services supported by additional services provided by a supply chain and contractors. These activities are carried out on client premises nationwide.

The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

• Stakeholders are identified and educated to follow the risk process when procuring services or goods.
• All medium or high risk suppliers will be audited.

Currently LCC have not identified any areas of high risk.

Initiatives

• Policy: this Policy will be implemented by HR Department and will be reviewed annually. The Executive Chairman has responsibility for ensuring adherence to this and relevant policies.
• Investigations/due diligence: will be conducted by whoever is procuring the service via questionnaire. Supplier/contractor statement of terms & conditions shall confirm declaration of Modern Slavery Code of Conduct.
• Training: the supplier/contractor & employee code of conduct will be covered at staff induction with refresher training provided by heads of departments.

Relevant Policies

• Whistleblowing Policy: LCC encourages all its workers, customers and business partners to report any concerns related to the direct activities or supply chains of LCC. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. LCC’s Whistleblowing – Speak Up procedure is designed to make it easy for workers to make disclosures without fear of retaliation.
• Code of Practice: LCC contracts of employment/handbook confirm employee code of conduct when representing LCC. LCC strives to maintain the highest standards of employee conduct and ethical behaviour when managing its supply chain.  LCC is also committed to ensuring that its suppliers/contractors adhere to the highest standards of ethics. Suppliers/contractors are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect and act ethically and within the law in their use of labour. LCC works with suppliers/contractors to ensure that they meet the standards of the code and improve their worker’s conditions. Any serious violations of LCC code of practice will lead to the termination of the business relationship.
• Anti-bribery: LCC is committed to the highest standards of ethical conduct and integrity in its business activities. This policy outlines the Company’s position on preventing and prohibiting bribery, in accordance with the Bribery Act 2010. The company will not tolerate any form of bribery by, or of, its employees including any individual or corporate entity associated with the Company or who performs functions in relation to, or for an on behalf of, the Company including, but not limited to, directors, agency workers, casual workers, contractors, consultants, seconded staff, agents, suppliers and sponsors.

Due Diligence

LCC undertakes due diligence when considering taking on new suppliers/contractors and regularly reviews its existing suppliers/contractors. The due diligence and reviews include:

Mapping the supply chain to assess particular product or geographical risk of modern slavery and human trafficking 

• Evaluating the modern slavery and human trafficking risks of each new supplier.
• Conducting supplier audits or assessments where risks have been identified on slavery and human trafficking.
• Invoking sanctions against suppliers/contractors that fail to improve their performance in line with implemented action plan or seriously violate our supplier code of conduct including the termination of the business relationship.

Training

LCC requires all members of HR department, managers with procurement responsibility and
operational managers to complete training on modern slavery.

Awareness

As well as training relevant staff, awareness of modern slavery issues shall be made available to all staff via:

• Issuance of details of the Modern Slavery Helpline 
• Details of basic principles of the Modern Slavery Act 2015
• Details of how employers can identify and prevent slavery and human trafficking
• How employees can flag up potential slavery or human trafficking issues to the relevant parties within LCC.