Introduction

Modern slavery is a crime and a 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.

Modern Slavery can take many forms that exploit individuals for the purpose of commercial or personal gain, amounting to a violation of a person’s human rights covered by the four key criminal areas under The Modern Slavery Act 2015.

These are;

• Slavery

• Servitude

• Forced and Compulsory Labour

• Human Trafficking

Lighthouse Communications has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are also 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 all of our contractors, suppliers and other business partners, and as part of our contracting processes, in the coming year we will 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 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 

Lighthouse Communications has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. Lighthouse Communications has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management 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 the issue of modern slavery in supply chains.

The modern slavery and human trafficking risk

Having a Modern Slavery Policy is key to:• Identify and assess potential risk areas in our supply chains• Mitigate the risk of slavery and human trafficking occurring in our supply chains; and• Monitor potential risk areas in our supply chains

Supply chain

Lighthouse Communications, and the majority of our suppliers, are not in industries with a high risk of modern dayslavery. In addition, our supply chains are primarily confined to Ireland and the UK, countries with a relatively lower risk of modern day slavery and human trafficking.

From a risk management perspective, we have identified areas we need to develop in conjunction with our supply chain, and a risk-based approach is under development. This approach is to include identifying and reviewing suppliers and vendors that fall within industries and/or countries that can carry higher risk, including in respect of modern day slavery and human trafficking. 

Reporting knowledge or suspicion of slavery or human trafficking

All employees have a statutory obligation to report knowledge or suspicion of slavery or human trafficking. Any genuine suspicion or knowledge of slavery or human trafficking is to be immediately reported to the Managing Director, who will decide what further action, if any, is deemed necessary. 

Employees who raise concerns of slavery or human trafficking in good faith may do so without fear of discrimination or reprisal. These provisions do not replace any legal reporting or disclosure requirements. Where statutory reporting requirements and procedures exist, these must be fully complied with.

Learning

We want to help our employees, clients and suppliers to understand more about these issues and understand how to report any suspicions they may have related to modern slavery and human trafficking.

The topic of Modern Slavery, and our associated Anti-Slavery and Human Trafficking Policy, continues to be flagged in the induction training undertaken by new staff members.

Review 

This policy will be reviewed by the Managing Director on an annual basis. 

This policy does not give contractual rights to employees and we reserve the right to alter any of its terms at any time. We will notify applicable parties in writing of any changes which may affect them.

This statement was approved by the Board of Lighthouse Communications.

Stephen Smith

Managing Director

30 July 2020