LHi Group Ltd and its subsidiaries (“We”) are dedicated to making a difference through how we conduct our business. Accordingly, we have enacted this policy to ensure that our business never involves, supports, or tolerates any form of modern slavery or human trafficking.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which involve people being deprived of their liberty by another to exploit them for personal or commercial gain. This is why we maintain a zero-tolerance approach to modern slavery in our business, in our clients, and throughout our supply chain, and we are committed to acting ethically and with integrity in all our business dealings and relationships.

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.

We review this policy on an annual basis.

While Modern Slavery represents a serious risk to global human rights and our societies, our assessment is that we do not have a high risk of exposure to modern slavery in our business. This is based primarily on the fact that our core business is the provision of recruitment and staffing services for roles in the modern office environment, many of which require very high levels of expertise and education. We assess both the sectors in which we operate and the types of roles that we pursue for placement as being in low-risk categories.

To further reduce the risks of modern slavery appearing in our business, we train all members of staff on robust and ethical recruiting practices that are designed to identify and prevent any possible instances of modern slavery or other forms of labour abuse from entering or occurring within our service pipeline. This includes (but is not limited to) ensuring that all workers we supply have a verified right to work for the duration of their assignments, have received all required legal notices about their rights as employees, and have the right under their employment agreements to leave their assignment at any time without penalty for termination.

With these assessments and countermeasures in mind, we have identified the purchase of products and services as our highest areas of risk for the possibilities of modern slavery.

We are dedicated to ensuring all goods and services purchased by and through our business are sourced from transparent, free-trade sources with positive records in terms of human rights and the prevention of modern slavery. Specifically, this includes (but isn’t limited to) our purchases of electronics like laptops and phones, our purchases of services from technology support and SaaS services, and our purchases of office supplies like coffee, food, desks & chairs, and other common office equipment.

You must ensure that you read, understand, and always comply with this policy, even while working with or for other organisations. Our dedication to a business free of modern slavery includes not working with any person or organisation that utilises modern slavery in any way or at any time, even if it is not a part of our direct supply chain.

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 might 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 occurred or may occur in the future.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business, our client’s business, supply chains, or 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 chain or at the business of any client constitutes any of the various forms of modern slavery, raise it with your manager or with the Legal and Compliance Team.

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 because 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 or clients. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavorable treatment or retaliation 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.

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 comply with 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 comply with 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 ContractsTeam@wearelhi.com

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, supply chain, and clients must be conveyed to all suppliers, contractors, and business partners at the beginning of our business relationship with them and reiterated as necessary thereafter.

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 or organisations that violate this policy.

In pursuit of our dedication to not work for or with any person or organisation that engages in modern slavery, we have begun to incorporate the following language into all our client agreements moving forward:

LHi has a zero-tolerance policy to Modern Slavery, including all forms of forced or compulsory labour, servitude, enslavement, and human trafficking. Regardless of its legality, the client represents and warrants that it is not engaged in and does not tolerate any form of modern slavery within its organisation or supply chain and agrees to keep its supply chain free of any such practices. LHi reserves the right to immediately terminate this Agreement if a client is found to be in breach of this section. Any such termination will not result in any penalty, or additional cessation of rights to LHi as a result.