Introduction

At Lloyd & Jones, we recognise that modern slavery is a grave violation of human rights and a criminal offence. It encompasses various forms, including slavery, servitude, forced labour, and human trafficking, all of which involve the exploitation of individuals for personal or commercial gain by depriving them of their freedom.

To ensure that our business practices align with our ethical values, we have established a comprehensive Modern Slavery Policy. This policy outlines our commitment to preventing and detecting modern slavery and human trafficking within our supply chain and wider business activities.

We hold ourselves and our partners to the highest standards of ethical conduct and expect our contractors, suppliers, and other business partners to do the same. Our policy applies to all individuals working for us or on our behalf, including employees, directors, officers, agency workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

Through our Modern Slavery Policy, we are taking proactive steps to combat modern slavery and human trafficking and uphold the fundamental human rights of all individuals.

Responsibility

The Company bears overall responsibility for ensuring that this policy aligns with our legal and ethical
obligations, and that all individuals under our authority adhere to it.

The Company holds primary and day-to-day responsibility for implementing this policy, monitoring its
utilization and effectiveness, addressing any inquiries related to it, and conducting internal control system audits and procedures to ensure their efficacy in combating modern slavery.

Management at all levels are accountable for ensuring that those under their supervision comprehend and comply with this policy, and receive sufficient and regular training on it as well as the issue of modern slavery in supply chains.

We welcome your feedback on this policy and encourage you to suggest ways in which it can be enhanced. Comments, suggestions, and inquiries should be directed to the Group Supply Chain Manager.

Compliance

All individuals associated with Lloyd & Jones are required to read, comprehend, and adhere to the statement and policy regarding the prevention, detection, and reporting of modern slavery within our business or supply chains. It is the responsibility of all employees and those under our control to avoid any actions that may violate this policy.

If you suspect or believe that a conflict with this policy has occurred or may occur in the future, you must promptly notify your line manager or a company Director.

We encourage individuals to report any concerns or suspicions of modern slavery in any part of our business or supply chains, and we will support those who raise genuine concerns in good faith. We are committed to ensuring that no one experiences any negative consequences for reporting their suspicions of modern slavery, and if you believe that you have suffered any detrimental treatment*, you should inform your line manager immediately.

If the issue is not resolved, employees should follow our Grievance Procedure, which is outlined in the
current employee handbook.

*Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

Communication

As part of our induction process, all employees are trained on our policy regarding modern slavery in supply chains and the risks it poses to our business.

We will keep you updated on any changes through established communication channels. It is imperative that our zero-tolerance stance on modern slavery is communicated to all suppliers,contractors, and business partners from the beginning of our relationship and reinforced as necessary.

Breach of Policy

In the event of a breach of this policy, disciplinary action will be taken against any employee, which may lead to dismissal for misconduct or gross misconduct. Furthermore, if any individuals or organizations working on our behalf violate this policy, we reserve the right to terminate our relationship with them.

David Cousins
Group Supply Chain Manager
Dated 26/10/2023 – Review Due October 2024

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