Modern day slavery and human trafficking statement

Introduction

Laker BMS Ltd has a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking do not take place anywhere in our business or supply chains.

This statement sets out the steps we have taken during the period covered to understand potential modern slavery risks related to our business and to implement appropriate measures to prevent modern slavery and human trafficking.

Our Business and Supply Chains

Laker BMS Ltd was founded in 1978 and provides building management and maintenance services. Our delivery covers installed building system support services to social housing providers, corporate clients, private landlords, property management agents and residential customers across Central England, Wales, London and the South East.

We employ approximately 80 people, the majority of whom work in mobile operational teams under the supervision of contract or area managers.

Our supply chain includes (but is not limited to) building materials and merchants, specialist subcontractors, plant and equipment suppliers, utilities and compliance service providers, and agency labour providers where required.

Relevant Legislation and Standards

Our approach is informed by applicable UK legislation and guidance, including:

• Modern Slavery Act 2015 (section 54)

• UK employment legislation (including the Employment Rights Act 1996 and National Minimum Wage Act 1998)

• Right to work and illegal working controls (including the Immigration, Asylum and Nationality Act 2006)

• Whistleblowing protections (including the Public Interest Disclosure Act 1998)

• Data protection legislation relevant to reporting and record keeping (including UK GDPR and the Data Protection Act 2018)

Risk Assessment

We undertake a proportionate risk-based approach to assessing modern slavery risks across our supply chain. Our risk assessment considers factors such as:

• The type of goods and services provided and the labour profile associated with them

• Use of agency labour and subcontracting tiers

• The potential presence of vulnerable groups (including migrant labour and low-paid workers)

• Geographic and sector risk factors relevant to construction and maintenance services

• Supplier performance, reputation and compliance history

Supplier Due Diligence

We conduct due diligence on new suppliers during onboarding and review existing suppliers periodically. Our controls may include:

• Reviewing supplier policies and procedures relating to labour standards and ethical sourcing

• Confirming compliance with applicable employment law, right-to-work checks and fair working practices

• Requesting evidence of insurances, relevant accreditations and competence

• Auditing supplier performance (including health & safety arrangements, labour practices and contractual controls), where appropriate to risk

• Requiring corrective actions and improvements where gaps are identified

• Reserving the right to suspend or terminate supplier relationships where serious concerns are identified or where suppliers fail to improve

We expect suppliers to confirm that:

• They do not use forced, compulsory or slave labour, or human trafficking

• Workers are employed voluntarily and are free to leave employment subject to lawful notice

• Workers are provided with written terms and conditions of employment

• Wages are paid in line with legal requirements and are not unlawfully withheld

• Identity documents are not retained unlawfully and are not used as a condition of employment

If we become aware of credible allegations of modern slavery or human trafficking within our supply chain, we will take immediate and proportionate action, which may include escalation to relevant authorities.

Policies and Governance

The following internal policies support our approach to preventing modern slavery and human trafficking:

• Whistleblowing Policy – encourages employees, customers and suppliers to report concerns without fear of retaliation, using confidential reporting routes.

• Code of Conduct – sets expectations for ethical behaviour and compliance by employees and those acting on behalf of Laker BMS.

• Procurement / Supply Chain Controls – support due diligence and responsible sourcing.

Overall accountability for this statement sits with the Directors of Laker BMS Ltd, with day-to-day oversight delivered through management arrangements for recruitment, procurement and contract delivery.

Awareness and Training

• We promote awareness of modern slavery risks and indicators among employees and relevant subcontractors/suppliers. Our approach includes:
• Induction and periodic briefings covering modern slavery awareness and reporting routes
• Inclusion of relevant information and reporting contacts within internal handbooks where appropriate
• Use of toolbox talks and targeted communications to operational teams
• Where we engage external HR or compliance support (such as THSP), this is to strengthen recruitment controls, including eligibility/right-to-work checks, which are also verified internally prior to employment offers.
• We are members of and draw on resources from initiatives such as Stronger Together, using training and guidance to continually improve our approach.

Measuring Effectiveness

We monitor the effectiveness of our approach through proportionate indicators such as:

• The number/percentage of employees completing awareness training

• Supplier and subcontractor engagement with relevant standards and expectations

• The number of reports or concerns raised and how quickly they are escalated and addressed

• Outcomes of supplier reviews/audits and completion of corrective actions

Review Period and Approval

This statement covers the period 3 January 2026 to 2 January 2027 and will be reviewed at least annually.

Approved by:

James Lakey, Managing Director

Date: 3rd January 2026