LSL Group Modern Slavery 2018

In accordance with the Modern Slavery Act 2015 (Act), LSL Property Services Plc (LSL) has published this statement on behalf of its relevant subsidiary companies[1] (LSL Group) (Statement).  This Statement sets out the steps that members of the LSL Group have taken during the financial year ending 31st December 2018 to prevent modern slavery and human trafficking from occurring within their businesses and supply chains. 

Introduction

In accordance with the Modern Slavery Act 2015 (Act), LSL has published this statement on behalf of its relevant subsidiary companies1 (LSL Group) (Statement). This Statement sets out the steps that members of the LSL Group have taken during the financial year ending 31st December 2016 to prevent modern slavery and human trafficking from occurring within its business and supply chains. The initiatives included in this Statement will continue to be implemented and developed during 2017 and will be reported on during 2018.

LSL Group Businesses

LSL through its subsidiaries is a leading provider of residential property services to its key customer groups.

For further information about LSL's services please visit www.lslps.co.uk

To reflect the increased importance of LSL’s Financial Services businesses, the LSL Board has decided to update financial reporting effective from 1st January 2019. From 1st January 2019 LSL will report three segments: Estate Agency; Financial Services; and Surveying and Valuation Services. The Financial Services segment will incorporate all LSL’s Financial Services businesses. The Estate Agency segment will primarily incorporate the results from the Estate Agency networks (Your Move, Reeds Rains, LSLi and Marsh & Parsons) and Asset Management. The Surveying and Valuation Services segment is unchanged.

Some sections of LSL’s financial reporting for the financial year ending 31st December 2018 contain information based on two segments (Estate Agency and Surveying and Valuations Services) and others contain information based on the new three segment reporting, to reflect the changes effective from the 1st January 2019.

As at 31st December 2018, LSL through its subsidiaries employed circa 5,463 people across the UK, where its business operations are entirely based.  

LSL Group Supply Chains

Members of the LSL Group have established direct relationships with a number of primarily UK-based suppliers who deliver a variety of services including: professional services , utilities and telecoms, and facilities management. As part of its service delivery, members of the LSL Group procure services not just for themselves, but also for the benefit of some of the customers of other group companies (including property management services and contractors).

The vast majority of services are procured via specialist individuals employed or engaged by members of the LSL Group.

LSL Group Policies and Contractual Provisions

LSL Group has a dedicated anti-slavery and human trafficking policy (the Policy) which works in combination with LSL Group’s established whistleblowing policy. Both policies form part of the LSL Group’s Combined Ethics Policy which applies to all LSL Group employees.

The Policy has two main aims:

The Policy was last reviewed during the 2018 financial year and will continue to be reviewed and updated annually as our understanding of the potential risks develop.

In addition, the LSL Group continues to implement provisions within its supply agreements which place prevention, control and notification measures on suppliers. This language is reviewed periodically.

We expect our suppliers to adopt the same high standards as we do and to have fair employment practices. To assist with this in 2018 we developed a Supplier Code of Conduct (Code) compliance with which is compulsory for all existing and new suppliers. The Code sets out the standards which we expect our suppliers to comply with in relation to working hours, wages and benefits, health and safety in the work place and prohibits the use of forced, compulsory and child labour. We may cease to engage suppliers if they fail to comply with the Code.

LSL Group Due Diligence

The LSL Group continues to identify its supply chains as the main area of risk and exposure to modern slavery.

During 2018, the LSL Group continued with its risk assessment of significant suppliers (who were identified by reference to total expenditure). The results showed:

LSL Group Areas of Risk

The LSL Board continues to believe overall exposure to modern slavery for members of the LSL Group is considered to be lower than other sectors given that the residential property services sector in which these businesses operate, the types of services they procure and the fact that these business operations and those of the majority of its suppliers are primarily based in the UK.

Notwithstanding the above, members of the LSL Group again this year consider that the procurement of recruitment and facilities services and the use of subcontractors are practices which may bring about increased risks of modern slavery within supply chains.  

To mitigate the risk that stems from supply chains, LSL developed the Code in 2018 and has made it compulsory for all existing and new suppliers to comply with this.

Other mitigation comes in the form of continuing to have in place stringent checks on our recruitment agencies and ensuring our own internal recruitment processes meet the minimum legal requirements.

As part of this, members of the LSL Group comply with all relevant legislation including the Immigration, Asylum and Nationality Act 2006 and ensure that all appropriate checks are carried out to maintain compliance.

LSL Group Training

The LSL Group does not underestimate the importance of ensuring that its employees are well equipped to identify and report any potential incidences of modern slavery. During the last year LSL Group has continued to deliver and develop bespoke training to members of senior management, procurement leads and other key employees across the LSL Group. 

All other LSL Group employees are made aware of the requirements under the Act and how to identify and report issues of modern slavery through the Policy.

KPI Monitoring

Set out below is a summary of the LSL Group’s performance against the KPIs set by the LSL Board in last year’s statement:

KPI from the 2017 Statement

Performance during 2018

Over the next year, the LSL Group intends to focus on the following:

 

This statement has been approved on behalf of the LSL Board on 30 April 2019.

Signed by Adam Castleton, Group Financial Officer on behalf of: 

LSL Property Services plc

your-move.co.uk Limited

Reeds Rains Limited

LSLi Limited

Marsh & Parsons Limited

e.surv Limited

1 This statement sets out the steps taken by your-move.co.uk Limited, Reeds Rains Limited, LSLi Limited, March and Parsons Limited and e.surv Limited
2 IT, accountancy, insurance, legal, marketing and recruitment services