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Modern Slavery Policy

Our Commitment

In accordance with the Modern Slavery Act 2015, IDMH Limited, t/a Lighthouse (“Lighthouse”) is committed to a work environment that is free from human trafficking, forced labour and unlawful child labour (collectively “human trafficking and slavery”). It strongly believes that it has a responsibility for promoting ethical and lawful employment practices. Modern Slavery is a crime and violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. 

Lighthouse will not knowingly use unlawful child labour or forced labour in any of the utilities and/or other commodities, products and/or services it provides, nor will it accept commodities, products and/or services from suppliers that employ or utilise child labour or forced labour.

Lighthouse has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all our business dealings and relationship. We implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. 

Supply Chains

Lighthouse is committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from our contractors, suppliers and other business partners, and as part of our contracting processes. We include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards. 

This policy applies to all persons working for us, or on our behalf of Lighthouse in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third party representatives and business partners. 

Responsibility for the Policy 

The Directors of the business have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. Our Directors have primary and day-to-day responsibility for ensuring that this policy is effectively communicated with third parties to the business. Directors are responsible for any queries, auditing internal control systems and procedures to ensure they are effective in the control of countering modern slavery. Line managers at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and issue of modern slavery in supply chains. 

Any member of our staff is able to comment and make suggestions of how the policy may be improved. Comments and suggestions are encouraged and are to be addressed to the Head of People. 

Compliance with the Policy

All Lighthouse staff must read, understand and comply with this policy. The prevention, detection and reporting of modern slavery in any part of our business or supply chains, is the responsibility of all those working for Lighthouse or under our control. The following guidelines are set out as below:

  • Staff are required to avoid any activity that might lead to, or suggest, a breach of this policy;
  • Staff must notify management as soon as possible if they believe, or suspect, that a conflict with this policy has occurred or may occur in the future;
  • Staff are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage;
  • If any member of staff believes and / or suspects a breach of this policy has occurred or that it may occur, they must notify management or report it in accordance with our Whistleblowing Policy as soon as possible; 
  • If staff are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chain constitutes any of the various forms of modern slavery, they must raise it with management, the Directors or the Head of People. 

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring on one suffers any detrimental treatment as a result of reporting in good faith, their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. 

Communication and Awareness of this Policy 

This policy is distributed to all employees, associates and subcontractors of Lighthouse. A zero-tolerance approach to modern slavery is communicated to all suppliers, contractors and business partners at the outset of the business relationship; it will be reinforced regularly thereafter. Breaches of this policy will be dealt with in the appropriate manner. We may terminate any business relationship with any third party if there is a known breach of this policy.