Anti-Slavery and Human Trafficking Policy

Policy Statement

This policy applies to all persons working for Lighthouse or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors and suppliers.

Lighthouse strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains.

We expect that our suppliers will hold their own suppliers to the same high standards.

Commitments

Modern Slavery and Human Trafficking

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking.

Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

Commitments

We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

• We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
• The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
• We are committed to engaging with our suppliers to address the risk of modern slavery in our operations and supply chain.
• We take a risk-based approach to our contracting processes and keep them under review.
• We may require:
• employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct
• Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code of Conduct.
• As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.
• If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationship.

Appendix 1

Code of Conduct

Doing the right things

We all have a role to play in leading by example. This could either be through managerial responsibility or through the standards we uphold in our day-to-day roles. We all have the responsibility to be a good role model, to support each other and to promote a culture of honesty, integrity and equality through our behaviours and the decisions we make.

This Code of Conduct is designed to be a starting point, a guide to help you when faced with these sometimes difficult decisions. It shows who we are and what we value. By thinking, working and behaving in the manner outlined in this Code, we will all contribute to our shared success.

Whether we are Lighthouse Security employees or in the supply chain working on Lighthouse Security’s behalf, we’re all accountable for behaving responsibly, ethically and legally in every aspect of our daily work.

In this code of conduct we cover six different areas:

• Safety, Security and the Environment
• Personal conduct
• How we treat people
• Working with our suppliers
• Getting help and reporting concerns
• Your responsibilities

Safety, Security and the Environment

Safety and security are at the heart of everything we do to protect our people, the public and the environment. Without delivering on this priority, we will lose trust, and with that, the right to operate this business.

We are all personally accountable for delivering our work safely, securely and in an environmentally responsible way, and managers in particular are accountable for setting clear direction, leading by example and demanding the highest standards in these respects.

We believe:

• Safety, security and environmental protection are everyone’s personal accountability and are delivered through personal ownership and action
• All events or incidents leading to injury are preventable
• Managers must lead by example, setting clear direction and coaching so we all achieve the highest standards
• Excellence in safety and security is achieved by our employees, contractors and suppliers all working together towards shared goals.

Make sure you follow procedures correctly, challenge unsafe practices and behaviours, and report concerns promptly.

Most importantly, intervene if someone is putting themselves or others at risk – if an incident were to occur, don’t find yourself saying ‘if only I’d done something to prevent it’ afterwards.

Any safety and security information you require will be available via your manager.

Personal Conduct

Responsible business conduct starts with each of us. We all have a duty to conduct ourselves in an ethical and professional manner, in compliance with the law and our policies. Whether it’s our commitment to cyber-security; our use of social media; not abusing drugs or alcohol; keeping ourselves and others safe; avoiding conflicts of interest; or preventing fraud and theft; or any other business activity, we all set and maintain the standards of our personal conduct. By trusting each other to behave in this way, we will all be able to perform at our best.

If you’re concerned or have any questions about any of these issues or would like further advice on how they apply to you personally, you can discuss them with your manager.

How we treat people

We are kind and respectful of each other. We believe everyone should be able to bring their own strengths and experience to contribute to our mission, which is why we promote equal opportunity, diversity and inclusion across our organisation. Everyone has a right to be treated with dignity and respect, and so we demand a workplace which is free of any form of discrimination, harassment or bullying.

By working for or with Lighthouse Security, it is your responsibility to ensure this positive environment is encouraged and maintained.

Please speak to your manager for a copy of Lighthouse Security’s Equality and Diversity policy.

Working with our suppliers

We cannot deliver our mission on our own. We deliver our mission via partnerships with our suppliers. Without them, we cannot achieve this, so it is crucial that we create and maintain these relationships in an open, fair and honest way, promoting a culture of mutual success.

Getting help and reporting concerns

We conduct our business openly, legally and with integrity. To continue this, it is crucial that everyone employed by Lighthouse Security or working on our behalf knows where to go for help or advice.

You are empowered to raise concerns knowing that they will be treated seriously, and where necessary, acted upon. Where you see or suspect unlawful activity in our business you must report it.

We are committed to ensuring that reporting a concern is not itself a cause of anxiety or fear. We don’t tolerate retaliation, victimisation, or discrimination against employees who raise concerns.

Please access help from the following support routes:

• Operations Manager
• Managing Director

Your responsibilities

The attitudes, behaviours and expectations outlined in the Code, and contained in our existing policies and procedures, are key to the success of our business. They describe who we are, and all Lighthouse Security employees are expected to uphold them in line with the law and our other obligations.

Be a role model for Responsible Business Conduct, and if you are unsure how to respond in a difficult situation, the Code is here to guide you. If you see or suspect any breaches to the Code or any company policies, report them via the channels outlined in this Code.

Where breaches occur, the relevant policies will be enforced. You must co-operate fully and honestly with any internal investigations being carried out in relation to suspected breaches.

Any formally investigated and confirmed breach of policy or procedure could potentially result in disciplinary action against employees. This could result in a range of sanctions, up to and including dismissal, or for non-employees of Lighthouse Security it may result in permanent removal from site.