Modern Slavery & Illegal Workers

The LK Group

Modern Slavery & Illegal Workers Policy

Modern Slavery Policy

1 Overview and how we define Modern Slavery

This policy outlines our approach to Modern Slavery.

This policy applies to all employees, apprentices, consultants, officers, contractors, interns, volunteers, job applicants, agency and casual workers. It also applies to self-employed contractors, workers or agency workers, and anyone working for or on behalf of the Company.

This policy does not form part of your contract of employment, and we reserve the right to amend it at any time.

Slavery, child labour and human trafficking are serious crimes and a violation of fundamental human rights. There are various forms of ‘Modern Slavery’ which deprives victims of their liberty and usually involves financial exploitation.

An ‘illegal worker’ is a migrant worker who is working in a host-country without the proper entitlement and authorisation to do so.

At The LK Group we conduct our business fairly, ethically and with respect to fundamental human rights and the law. We are fully committed to the prevention of all forms of slavery, forced labour or servitude, child labour and human trafficking, both in our business and in our supply chains. We will not tolerate it.

The Company’s Office Manager assumes the role of Anti-Slavery Officer (ASO) and is responsible for this policy.

Failure to comply with this policy may result in disciplinary action, including dismissal, or termination of the contract between you and the Company. It could also involve other legal steps being taken against you.

2 Preventing slavery and human trafficking in our business

The company makes appropriate checks on all employees, recruitment agencies and suppliers, to know who is working for, or on behalf of us.

The Company provides every employee with a written contract of employment. We pay every employee in accordance with the law. We comply with our legal obligations to ensure the health and safety of all our employees and workers, including in relation to working hours, rest breaks and holidays.

3 Ensuring all employees hold a legal right to work in the UK

The Company will ensure that all our employees are entitled to work in the UK and we do not discriminate against anyone because of their nationality.

Where applicable, we ask all employees to provide us with their national insurance number and the P45 form from their previous employer. Where this is not available, they are required to complete a P46 form, which we then send to the HMRC for verification. We also require new employees to provide a driving licence or other photo identification to verify contact details.

Issue No. 4 1 May 2022

The LK Group

Modern Slavery & Illegal Workers Policy

Where applicable we will also check any employee’s right to work documents.

We will obtain the relevant documentation detailed on the Government issued ‘Right To Work Checklist’ and ensure that:

the documents are not expired (except UK passports, which may be expired) photos in the documents look like the employee

the date of birth on the document seems consistent with the employee’s appearance

the visa covers the type of work they will be doing (including any limit on the number of hours they can work)

if two documents have different names on, there is a good reason for this, such as marriage or divorce

We will continue to seek advice from the Government and other sources to ensure that our practices conform to current legislation.

The company reserves the right to periodically check or request documentation in relation to an employee’s right to work in the UK at any time.

4 If you are one of our Suppliers

If you supply the Company with goods or services, you must assess your business and supply chains and confirm to our ASO that you comply with your legal obligations, in relation to Modern Slavery, and are committed to ensuring there is no slavery, forced labour or servitude, child labour or human trafficking taking place in your business, or any of your supply chains.

If you breach this policy or are found to have slavery or human trafficking in your business, or knowingly in your supply chain, the Company may terminate the contract with you and pursue its legal remedies against you.

5 If you are an Employee or Worker providing services for us

You must immediately report any suspicions of Modern Slavery or human trafficking in our business or supply chains to our ASO. Our ASO will investigate and report to our Board of Directors, within a reasonable time, on actions which may require to be taken.

All employees are required to make the Company aware of any changes to their personal circumstances which may affect their right to work in the UK.

You will not suffer any detrimental treatment as a result of reporting any genuine concerns, raised in good faith, under this policy. This applies, even if after investigation, they are found to be mistaken. If you believe that you have suffered any such treatment, you should immediately inform our ASO and if you are an employee, refer to our Grievance and Whistleblowing Policies.

Issue No. 4 2 May 2022