Modern Slavery Awareness Policy Statement

Introduction

LCM LABOUR LIMITED (“LCM”) has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or in any of its supply chains.

LCM operates as an employment business working in partnership with recruitment agencies, supplying both skilled and unskilled staff for the temporary labour market. We are aware of the potential for being targeted by traffickers and unlicensed gangmasters.

Our own processes around modern slavery awareness ensure that our employees are alert to the signs of exploitation and we work with our partner agencies to ensure that they have modern slavery awareness processes in place in their role as a work finder.

LCM accepts that it has a responsibility through its due diligence processes to ensure that workers are not being exploited, that they are safe, and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications

Our Policy on Slavery and Human Trafficking

LCM is committed to ensuring that we take all reasonable steps to ensure that there is no modern slavery or human trafficking within our business or supply chain
Workers are free to choose to work for their employer and to leave their employment upon reasonable notice.
All workers will be provided with a clear contract for services, which complies with local legislation
All workers will be treated in a fair and equal manner and with dignity and respect
Any form of discrimination, victimisation or harassment on the grounds of marital or civil partnership status, sex (including gender reassignment), race (including colour, ethnic and national origin, nationality) disability, sexual orientation, having or not having dependents, religious belief or political opinion, age, trade union activity and offending background will be prohibited
All applicable laws and industry standards on wages, benefits, working hours and minimum age will be adhered to in all countries of operation. Workers will be paid at least the National Minimum Wage
No child labour will be used
No young persons under the age of 18 will be used to work at night or for any hazardous work and their work should not harm the young person’s education, health or physical, mental, moral or social development
No recruitment fees are charged to workers under any circumstances

Organisational Structure/Supply Chain

We have inbuilt compliance checks within our payroll systems to look for modern slavery indicators such as duplicate bank accounts, duplicate email addresses, large numbers of workers residing in the same address.

In order to protect the integrity of our processes, we expect our partner agencies, suppliers and end clients to aim for high ethical standards and to operate in an ethical, legally compliant and professional manner and we will only partner with agencies who have met our strict audit checks.

Risk Assessment

Due Diligence

All prospective partner agencies are audited prior to onboarding at which time front line modern slavery awareness processes are checked.
All workers will always be interviewed in person or via video interview by our partner agencies, with questions specifically targeted to try and identify whether they are subject to any form of modern slavery
We operate a policy of workers only being able to have their wages paid into a bank account that is in their name.
We check that all staff within our partner agencies who are responsible for recruiting and sourcing workers are trained and required to sign up to a new set of recruiter compliance principles that govern their methods of recruiting new staff
Marketing and media links in tackling hidden labour exploitation are issued to workers and displayed on partner agencies and client sites (where permitted)
Workers are provided with details of who to contact in respect of any concerns they may have in relation to modern slavery which is provided in the worker handbook
LCM will conduct quarterly visits to partner agencies to ensure that all processes are being adhered to
Worker welfare surveys will be conducted every six months to ensure the ongoing wellbeing of our workers
Worker welfare checks will be carried out by LCM during the annual audit and if able during quarterly visits.

Training

LCM workers are provided with an induction either by the partner agency or the end client which includes information on the sources of help should they, or their colleagues/friends be concerned about Modern Slavery.

All employees of LCM will attend Modern Slavery Training to educate them about Modern Slavery and spotting the potential signs of Modern Slavery.

All partner agencies are also expected to attend Modern Slavery Training which is checked during the audit process.

Safeguards

We aim to encourage openness and within our LCM Rewards App, we have a dedicated anonymous reporting process where workers can raise any concerns. We also have a whistleblowing policy in place with a confidential email address.

We will support anyone who raises a genuine concern and ensure that they receive the appropriate support required.

As a GLAA licence holder, we are committed to sharing any concerns with the appropriate public bodies if we identify any issues surrounding Modern Slavery.

Communication and awareness of this policy

Our zero-tolerance approach to modern slavery will be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Review

Following its initial adoption, this Modern Slavery Policy Statement will be reviewed by the Company Director on a regular basis (at least annually) and may be amended from time to time.

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes LCM LABOUR LIMITED Modern Slavery Statement for the financial year 2024/2025.

Last Updated: 11/ 2024