Modern day slavery and human trafficking statement

Introduction

At Laker BMS Ltd, we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking.

Our Business and Supply Chains

Laker BMS Ltd. was founded in 1978 and is a national provider of building management and maintenance services. Our central delivery solutions encompass installed building system support services to social housing providers, corporate clients, private landlords, property management agents, and residential customer across Central England, Wales, London and the South East. We have a workforce of around 80, the majority of whom are mobile teams under the supervision of contract or area managers.

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier's reputation, respect for the law, compliance with health, safety and environmental standards, and references.

Risk Assessment

We have conducted a risk assessment of our supply chain to determine our response and the risk controls that we implement. This included:

• The business services rendered by the suppliers
• The presence of vulnerable demographic groups
• Analysis of labour and human rights groups

Supplier Due Diligence

Laker BMS Ltd. conducts due diligence on all new suppliers during on-boarding and on existing suppliers at regular intervals. This includes:

• Assessing risks in the provision of particular services
• Auditing the suppliers, and their health and safety standards, labour relations and employee contracts
• Requiring improvements to substandard employment practices
• Sanctioning suppliers that fail to improve their performance in line with our requirements

We require all suppliers to attest that:

• They don't use any form of forced, compulsory or slave labour
• Their employees work voluntarily and are entitled to leave work
• They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment
• They don't require employees to post a deposit/bond and don't withhold their salaries for any reasons
• They don't require employees to surrender their passports or work permits as a condition of employment

We haven't been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and report it to the authorities.

Policies

Laker BMS operates the following policies for identifying and preventing slavery and human trafficking in our operations:

• Whistleblowing Policy - we encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation. We provide a confidential helpline to protect the identity of whistle-blowers.
• Code of Conduct - our code encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.

Awareness

Laker BMS Ltd. has raised awareness of modern slavery issues amongst our employees:

• We developed an email notification focusing specifically on modern slavery
• During all recruitment we built in the advice of external consultants, The Health and Safety People (THSP). THSP ensure eligibility to work measures are undertaken for directly employed staff. These are then verified internally prior to an offer of employment
• We joined ‘Stronger Together’ which provides businesses with practical training, resources and collaborative working opportunities to help create responsible trafficking and slavery HR processes. We attended an online course relating to the construction industry and accessed resources which we are incorporating into the review of our understanding of Modern Slavery and Human Trafficking

Training

In addition to the awareness programme, Laker BMS Ltd. has developed a training program:

• We updated our staff and training/induction handbooks to include the contact number for the Modern Slavery Helpline should employees encounter a suspected case of modern slavery
• This corresponded with our provision of inhouse training via a newly developed toolbox talk to increase awareness of slavery and trafficking and the signs to look out for when working with colleagues who may be experiencing modern slavery

Measuring How We Are Performing

Laker BMS Ltd. has defined a set of key performance indicators and controls to combat modern slavery and human trafficking in our organisation and supply chain. These include:

• How many employees have completed training
• How many suppliers have rolled out an awareness and training programme
• How many reports have been made by our employees that indicate their awareness of and sensitivity to ethical issues

Review

This statement covers 1 April 2024 to 31 March 2025 and has been approved by the Directors of Laker BMS Ltd. The Directors will review the operation of this policy annually, or more regularly if we identify any non-compliance or problem preventing slavery and human trafficking in our operation and supply chain.

Signed:

James Lakey, Managing Director

Date: 23rd March 2024