Policy on Preventing Hidden Labour Exploitation

POLICY STATEMENT

Lapwing UK. Limited (hereafter, The Company), commits to developing and adopting a proactive approach to tackling hidden labour exploitation.

Hidden labour exploitation is exploitation of job applicants and workers by third party individuals or gangs other than the employer or labour provider including rogue individuals working within these businesses but without the knowledge of management. It includes forced labour and human trafficking for labour exploitation; payment for work-finding services and work-related exploitation such as forced use of accommodation. It is understood that it is often well hidden by the perpetrators with victims, if they perceive of themselves as such, reluctant to come forward.

Coverage

This Policy covers the companies owned, rented or leased premises which are operated directly by the company’s permanent or temporary staff.

Responsibility

The Managing Director has overall responsibility for employment decisions. The following staff have specific responsibilities for various aspects of this policy: Operations Manager: Selection & Recruitment (in conjunction with MD). Department Managers: Selection & Recruitment, HR Manager: Policy Enforcement & maintaining Employment Records, Warehouse Manager: Direct line manager of any warehouse/temporary staff. Compliance Manager: Internal Auditing.

Policy Commitments

The Company shall:

1. Ensure appropriate managers complete “Tackling Hidden Labour Exploitation” training and take responsibility for developing and operating company procedures relevant to this issue.
2. Accept that job finding fees are a business cost and will not allow these to be paid by job applicants. The Company will not use any individual or organisation to source and supply workers without confirming that workers are not being charged a work finding fee.
3. Ensure that all staff responsible for directly recruiting workers are trained to be aware of issues around third-party labour exploitation and signs to look for and have signed appropriate Compliance Principles.
4. Ensure that labour sourcing, recruitment and worker placement processes are under the control of trusted and competent staff members.
5. Adopt a proactive approach to reporting suspicions of hidden worker exploitation to the Gangmasters Licensing Authority and police.
6. Provide information on tackling “Hidden Labour Exploitation” to our workforce through formats such as workplace posters, worker leaflets, induction & other training.
7. Encourage workers to report cases of hidden third-party labour exploitation, provide the means to do so and investigate and act on reports appropriately.
8. Positively encourage and support employees and agency workers to report such exploitation which may be occurring within their communities by either contacting the HR manager by email, phone or verbally or to contact either Stronger Together or the Police.
9. Require labour providers and other organisations in the labour supply chain to adopt policies and procedures consistent with the above.

This policy was reviewed and adopted 1st December 2024
Review by 31st December 2025