Modern Slavery Policy

Introduction

This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 31 March 2021. 

LXDUK Ltd (‘the Company’, ‘we’, ‘us’ or ‘our’) is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values. 

Organisational structure

LXDUK Ltd has business operations in the United Kingdom as well as:

• Japan

We operate in the Raw Materials sector. The nature of our supply chains is as follows: We work with our main supplier in Japan that own Limex materials. TBM (Times Bridge Management) operate multiple manufacturing facilities where Limex is sourced, prepared and shipped to the UK.

For more information about the Company, please visit our website: www.lxduk.com.

Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. 

These include the following: 

• Recruitment and selection policy– We conduct checks on all prospective employees to verify that they are eligible to work in the UK and undergo DBS checks. We Follow a strict recruitment process which ensures people are treated equally and rewarded and benefited in line with legislation in the UK.
• Supplier code of conduct– We operate this policy to ensure our suppliers operate in full compliance with the laws, rules and regulations of the countries in which they operate, and to seek similar commitments across their own supply chain.
• Staff code of conduct– We are committed to the fair treatment of all staff. Our staff code of conduct reflects our core values and expected behaviours. The code of conduct makes it clear that we have a zero-tolerance approach to modern slavery.
• Procurement policy– We want to make sure that potential suppliers are committed to ensuring that slavery and human trafficking is not taking place within their own supply chains. Our procurement policy and supporting procedures set out controls and checks undertaken to help verify this.

We make sure our suppliers are aware of our policies and adhere to the same standards.

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures: 

• Internal supplier audits.
• External supplier audits.

Our due diligence procedures aim to:

• Identify and action potential risks in our business and supply chains.
• Monitor potential risks in our business and supply chains
• Reduce the risk of slavery and human trafficking occurring in our business and supply chains.

Risk and compliance

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:

• Evaluating the slavery and human trafficking risks of each new supplier.
• Creating an annual risk profile for key suppliers.
• Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping.

We consider that we operate in a high-risk environment because The risks in this case are high from our supply chain source of material, sourcing Limex and producing are in countries where modern slavery can occur, especially in labour. we do not expect this from our registered supplier in Japan as they have strict measures in place, but through their own supply chains in other countries that they may not have full control over. Our operations in the UK are low risk as we can control who we work with and for.

We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will require that supplier to remedy the non-compliance.

Effectiveness

The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPIs are as follows:

• We will contact suppliers to enquire about their modern slavery practices every12 months.
• We will train our staff about modern slavery issues and increase awarenesswithin the Company.
• We will carry out a regular audit of suppliers – 70% of suppliers each year.

Training our staff

The Company requires its staff to complete training and ongoing refresher courses on slavery and human trafficking. The Company’s training covers:

• How to identify the signs of slavery and human trafficking.
• What initial steps should be taken if slavery or human trafficking is suspected.
• How to escalate potential slavery or human trafficking issues to the relevant parties within the Company.
• What external help is available.
• What steps the Company should take if suppliers in its supply chain do not implement anti-slavery policies in high-risk scenarios, including their removal from the Company’s supply chain.

Next steps

In the next financial year, we intend to take the following steps to tackle slavery and human trafficking by: 

• introducing new policies and procedures or organising wider training for the internal team working on modern slavery and human trafficking issues

The statement was approved by the board of directors.

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Omar Anwar, Director
LXDUK Ltd

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