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Modern Slavery Statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the LOD Group’s modern slavery and human trafficking statement.

1. Modern Slavery Act statement

The LOD Group recognises that modern slavery is a crime and a gross violation of fundamental human rights.

The LOD Group takes a zero-tolerance approach to modern slavery and human trafficking. The use of any such practices is strictly prohibited in our operations and supply chain. We have in place, and are committed to continuing implementation of, policies, systems and controls aimed at ensuring that modern slavery and human trafficking is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.

The Group’s existing policies and procedures were considered sufficient for detecting and addressing risks of slavery and human trafficking in our supply chains during the last financial year. Our risk assessment processes did not identify any significant risks. Subsequently the LOD Group has been reviewing our processes and making improvements in how we assess and address Modern Slavery risks with our suppliers and clients, and improving our training to key employees in this area.

2. Supply chain

The LOD Group is taking a risk-based approach to identifying and working with high risk suppliers, based on a careful risk assessment across the Group’s operations, and specific policies and procedures which complement our policies requiring all staff to act legally and ethically in everything we do.

Attention is focussed on our high risk spend areas and on raising staff awareness to ensure all goods and services are sourced responsibly.

3. Staff

The Group has a clear framework of rules and behaviours which underpin its zero-tolerance approach. Furthermore, the Group encourages the reporting of any concerns or breaches so that they can be dealt with appropriately in accordance with our policies and procedures.

The LOD Group requires that employees and contractors demonstrate their eligibility to work in the UK or the overseas jurisdictions they work in. The LOD Group recruits all staff directly.

4. Approval

This statement was approved by the Board of Surf (Bidco) Limited on 25th November 2021 and signed on its behalf by Tom Hartley, CEO. Surf (Bidco) is the parent company of all the operating companies in the LOD Group worldwide, including the companies in the Group supplying any goods and services in the UK, namely Lawyers On Demand Limited, SYKE Legal Engineering Limited and Spoke Law Limited.