Anti-slavery and Human Trafficking Statement

This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by LC MEDIA Limited (“we” or “our”) to prevent modern slavery and human trafficking in its business and supply chains during the year ending 31 December 2017.

Our Business Structure

We have a zero-tolerance approach to modern slavery and human trafficking within our business and supply chains. We do not support, endorse or promote the use of such practices and do our duty to declare to the relevant authorities when we suspect that these activities may be taking place.

We supply recruitment/head hunting services and are not associated with any other companies therefore our statement only applies directly ourselves and the services that we provide.

Our Supply Chain

As a provider of recruitment/head hunting and consulting services our supply chain is deemed straight forward in contrast to other industries.

In the United Kingdom we work with a small range of suppliers who provide goods and services across a number of different categories, such as property and facilities management, IT and telecoms, marketing, legal and other services. Therefore, we have close relationships with our suppliers and good visibility of our supply chain.

Following a risk assessment of our company, supply chains and the procedures we utilize in the United Kingdom, we consider that there is a relatively low risk of labour exploitation or other forms of slavery and human trafficking occurring. We are none the less committed to preventing these practices from occurring within both our business and our supply chain, which is demonstrated by our policies and due diligence procedures as outlined below.

Our Policies

Our Anti-slavery and Human Trafficking Policy (“the Anti-slavery Policy”) reflects our commitment to implementing and effecting effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business and supply chains. The Anti-slavery Policy sets out our zero-tolerance approach to modern slavery and human trafficking. Every member of staff is expected to comply with the policy which includes raising any concerns and using the appropriate reporting channels at the earliest possible stage. We abide to a “Whistle Blowing” procedure that all our staff are encouraged to enact should they notice anything untoward relating to slavery and human trafficking. In particular the Whistleblowing Policy refers to a number of reporting tools designed to provide an open environment and honest communication. All reports will be fully investigated and remedial action and escalation to our board of directors will follow if appropriate.

Supplier Code of Conduct

We have a long-standing approach to supply chain responsibility and so expect our suppliers to agree and adhere to our ethical standards for doing business. These standards require suppliers to:

  • Never  hold a person in slavery or servitude or require a person to perform any form of forced or compulsory labour;
  • not arrange or facilitate the trafficking of any persons;
  • not purchase materials or services from companies who use involuntary labour or participate in human trafficking;
  • Act in accordance with applicable national and regional laws and regulations at all times.
  • treat and reward employees equally on the basis of the characteristics of their work.
  • Provide safe, hygienic, and healthy working environments for their employees whilst taking into account the specificity of the industry, sector or job specification.
  • Adhere to the governments minimum standards of pay;

Training

To ensure that awareness of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff where relevant to prepare them and provide them with as much knowledge to be prepared to act out and prevent the practice of such.

Due Diligence

We have written and adhere to the following:

  • Identify and assess potential risk areas in our supply chains;
  • Audit existing and prospective suppliers;
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains; and protect whistle blowers for reprisal or harm.

Final Statement

As an organisation, we are committed to building on what we do each year to prevent modern slavery and human trafficking.  Following a review of the effectiveness of the actions we have implemented to date, we intend to take the following further steps to combat modern slavery and human trafficking:

This statement was approved by the Managing Director of LC MEDIA Limited on 19 July 2018 and is made pursuant to section 54(1) of the Modern Slavery Act 2015.