This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and constitutes the LOD+SYKE Group’s modern slavery and human trafficking statement.
1. Modern Slavery Act statement
The LOD+SYKE Group recognises that modern slavery is a crime and a gross violation of fundamental human rights.
The LOD+SYKE Group is committed to the cause of preventing modern slavery and human trafficking.
We have in place, and are committed to improving, policies, systems and controls aimed at ensuring that modern slavery and human trafficking is guarded against within our organisation and in our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.
This year we took the following actions and made the following improvements in pursuit of our commitment to guarding against modern slavery in our organisation and supply chain:
a) the Group’s existing Anti-Slavery policy was reviewed and is being updated;
b) a risk assessment of all current suppliers was undertaken, focusing on higher risk sectors and jurisdictions, and no significant risks were identified;
c) we made improvements to how we deal with Modern Slavery in our contracting process with both suppliers and clients;
d) we developed LOD+SYKE’s stance on how to work with ad hoc suppliers with whom we do not have formal contracts (e.g. one off lunch suppliers);
e) we planned improvements to our training of relevant employees on this topic.
2. Supply chain
The LOD+SYKE Group continues to undertake regular, careful risk assessments across the Group’s supply chain, looking closely at those suppliers who work in high risk industries and in high risk jurisdictions.
We look to minimise risk in our supply chain via our contracting process, our day to day interactions with suppliers and via our policies and procedures that require our staff to act legally and ethically in everything we do.
Our attention is focussed on our high risk spend areas and on raising staff awareness to ensure all goods and services are sourced responsibly.
The Group has a clear framework of rules and behaviours which underpin its approach to tackling modern slavery risk. 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. Staff are made aware through our Whistleblowing Policy that there will be no disadvantage to them in reporting such issues and LOD welcomes and will investigate any issues or perceived issues.
The LOD+SYKE Group requires that employees and contractors demonstrate their eligibility to work in the UK or the overseas jurisdictions they work in. The LOD Group commits to ensuring: -
- all staff have a written contract of employment and that they have not had to pay any direct or indirect fees to obtain work.
- staff are legally able to work in the relevant country.
- information is given to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to.
- that we operate an open-door policy so that staff can discuss concerns with their managers as well as ensuring there is an anonymous and confidential route to flagging concerns via our whistleblowing process.
This statement was approved by the Board of Surf (Bidco) Limited 15th December 2022 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 LOD SYKE Services Limited.