Modern Slavery and Human Trafficking Statement

1.     Policy Statement 

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.

LAN Services Ltd (t/a Commercial Washrooms Ltd) has a zero-tolerance approach to modern slavery or human trafficking, 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.

This policy does not form part of any employee’s contract of employment, and we may amend it at any time.


2.     Policy Details 

2.1 Supply Chain

We wholeheartedly endorse the legislation as a crucially important development in tackling slavery and human trafficking and we will not trade or partner with any business or organisation which is involved in this shocking practice however remotely or indirectly. 

Our supply chains include a wide variety of services. We have will review the risks that these supply chains can present and whilst we consider our exposure to modern slavery to be limited, we expect our suppliers and contractors to be able to demonstrate a zero-tolerance approach to exploitation.  To this end, we expect our suppliers to comply with the Act, and maintain the right to terminate in the instance of any breach of this obligation.

As part of our procurement process, we will seek to engage with suppliers and contractors who confirm their compliance with the Act. 

2.2 Employees

We will ensure that our employees have a right to work in the UK. We will also promote to all our employees that Modern Slavery is a global problem that affects us all. 

Should we use workers from an agency, seasonal or temporary staff, we will ask the agent for proof that the workers have a legal right to work in the UK. 

2.3 Indicators of Modern Slavery

We are aware of the potential indicators of modern slavery and will monitor these as appropriate. 

Such signs may include:

  • Distrustful of authorities
  • Expression of fear or anxiety
  • Signs of psychological trauma (including post-traumatic stress disorder)
  • The person acts as if instructed by another
  • Injuries apparently a result of assault or controlling measures
  • Evidence of control over movement, either as an individual or as a group
  • Restriction of movement and confinement to the workplace or to a limited area
  • Passport or documents held by someone else
  • Lack of access to medical care
  • Limited social contact/isolation
  • Limited contact with family
  • Signs of ritual abuse and witchcraft (juju)
  • Substance misuse
  • Person forced, intimidated or coerced into providing services
  • Doesn’t know home or work address
  • Perception of being bonded by debt
  • Money is deducted from salary for food or accommodation
  • Threat of being handed over to authorities
  • Threats against the individual or their family members
  • Being placed in a dependency situation
  • No or limited access to bathroom or hygiene facilities
  • Unwanted/underage pregnancy
  • Inappropriate sexual behaviour
  • Incoherent/changing account of events
  • Repeating a story that you have heard elsewhere
  • Unexplained eagerness to leave a safe space/to work
  • Sexually transmitted diseases

2.4 Actions

Should we suspect that someone is being exploited, we will call the Modern Slavery Helpline on 0800 0121 700 or Crimestoppers anonymously on 0800 555 111.

If we suspect there is an immediate risk of harm, then we will call 999.


3.     Responsibility for the policy 

LAN Services Ltd has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

LAN Services Ltd 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. 

Staff should remain aware of this area and report any concerns immediately.


4.     Compliance with the policy 

The prevention, detection and reporting of modern slavery in any part of our business or supply chains are the responsibility of all those working for us or under our control.

You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify your line manager OR a company Director as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.

You 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 you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your line manager or company Director OR report it as soon as possible.

You should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive,

abusive and exploitative work practices in their own business and supply chains.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your line manager or company Director.

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 no 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.

Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

If you believe that you have suffered any such treatment, you should inform your line manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the current employee handbook.


5.     Breaches of this policy 

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.