LSL Group Due Diligence
Members of the LSL Group have identified their supply chains as the main area of risk and exposure to modern slavery.
During 2016, a two-stage risk assessment was commenced to identify possible risks of modern slavery within supply chains which has continued to run into 2017. The initial risk assessments have focused on significant suppliers (who have been identified by reference to total expenditure). This initial stage of the risk assessment enabled members of the LSL Group to attribute a risk rating to each supplier. Where a supplier was considered “medium” or “high” risk, further investigation was conducted to enable greater understanding of about the possible risks associated with the supply chain and consider whether further action is required.
In addition to carrying out due diligence exercises on existing suppliers, the working group is identifying measures that members of the LSL Group will benefit from including the development of supplier due diligence arrangements which form part of procurement processes.
LSL Group Areas of Risk
Overall exposure to modern slavery for members of the LSL Group is considered to be lower than other sectors given that the residential property services sector in which these businesses operate, the types of services they procure and the fact that these business operations and those of the majority of its suppliers are primarily based in the UK.
Notwithstanding the above, members of the LSL Group are not complacent and understand that the procurement of recruitment and facilities services and the use of subcontractors are practices which may bring about increased risks of modern slavery within supply chains. Accordingly, members of the LSL Group are taking the steps to mitigate such risks, including:
- requiring suppliers to implement due diligence procedures for its own suppliers and subcontractors; and
- having in place stringent checks on our recruitment agencies and ensuring our own internal recruitment processes meet the minimum legal requirements.
As part of this, members of the LSL Group comply with all relevant legislation including the Immigration, Asylum and Nationality Act 2006 and ensure that all appropriate checks are carried out to maintain compliance.
In the event that further risks are identified, members of the LSL Group will consider such risks and take appropriate steps to address any emerging risks.
LSL Group Training
Members of the LSL Group understand the importance of training employees to enable them to be able to identify risks of modern slavery. LSL is putting in place a training programme to ensure that senior management, procurement leads and LSL Group employees receive sufficient information and/or complete appropriate training to understand the requirements under the Act and how to identify and report issues of modern slavery. Each group identified has a different role to play in combatting modern slavery and therefore the information and/or training shall be tailored accordingly.
The LSL Board appreciate that the approach to combatting modern slavery will have to adapt over time in response to the findings following the completion of various risk assessments. The LSL Board intend to monitor the following KPI’s over the next financial year to measure how effective the processes have been:
- the number of employees who have received training on modern slavery risks; and
- the number of suppliers we have carried out a risk assessment.
This statement has been approved on behalf of the LSL Board on 29 June 2017
Signed by Adam Castleton, Group Financial Officer on behalf of:
LSL Property Services plc
Reeds Rains Limited