This statement is made pursuant to section 54(1) of the UK 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 is committed to the cause of preventing modern slavery and human trafficking.
Considering our business and the services we provide; we believe there is a low risk that modern slavery and human trafficking will occur within our business and supply chain. Nevertheless, we have in place, and are committed to continually 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 improved, and was approved in June 2023;
b) we developed clauses for the Group's legal team to use in contracts with suppliers who work in high-risk industries and in high-risk jurisdictions, for rolling out in the current year;
c) we have continued to conduct risk assessments on our suppliers as circumstances change, focusing on higher risk sectors and jurisdictions. No significant risks were identified during the year;
d) we commissioned an ESG review by an external third party, which included a review of our supply chain management and Modern Slavery policy. No material issues were identified. The reviewers noted that whilst individuals responsible for procurement decisions do take ESG related considerations (such as modern slavery) into account, there is an opportunity to create a system to do this more formally.
2. Subsequent events
In August 2023, the LOD Group became part of Consilio. During the current year we will align our approach and systems with Consilio to identify potential areas of risk in our supply chains, to mitigate the risk of modern slavery and human trafficking occuring in our supply chains, and to protect whistleblowers who raise concerns in this area.
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 Group requires that employees and contractors demonstrate their eligibility to work in the UK or the overseas jurisdictions they work in. The 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 on 23 November 2023 and signed on its behalf by Alan Hartley, director of Surf (Bidco) Limited. Surf (Bidco) is the parent company of all the operating companies in the LOD and SYKE 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.