1. Policy Statement

LC Investigation (“LCI”) is committed to conducting business ethically, transparently, and

with integrity in all areas of its operations. We recognise our responsibility to prevent

modern slavery, forced labour, servitude, human trafficking, and exploitation within our

business activities and supply chains.

LCI maintains a zero-tolerance approach to modern slavery and is committed to acting

professionally, fairly, and responsibly in all business relationships.

This policy is prepared in support of the principles contained within the UK Modern

Slavery Act 2015 and reflects the organisation’s commitment to ethical business

practices regardless of whether statutory reporting thresholds apply.

2. Organisational Structure, Business and Supply Chains

LC Investigation is a private sector professional services organisation specialising in:

• Compliance auditing

• Mystery shopping programmes

• Investigative services

• Operational risk and assurance services

• Field-based compliance verification activities

LCI operates across multiple jurisdictions through a combination of:

• Direct employees

• Approved contractors

• Specialist service suppliers

Our supply chains primarily include:

• Field audit and investigative personnel

LCI recognises that international operations may present varying levels of modern

slavery risk and therefore applies proportionate oversight and due diligence controls.

3. Policies Relating to Slavery and Human Trafficking

LCI maintains policies and operational controls designed to prevent slavery and human trafficking within its operations and supply chains, including:

• Ethical Business Conduct Policy

• Supplier Due Diligence Procedures

• Recruitment and Vetting Procedures

• Whistleblowing and Reporting Procedures

• Anti-Bribery and Corruption Policy

• Equality and Non-Discrimination Policy

• Data Protection and Confidentiality Policies All personnel engaged by LCI are expected to operate in accordance with applicable

laws, ethical standards, and professional conduct requirements.

4. Due Diligence Processes

LCI applies risk-based due diligence procedures in relation to slavery and human trafficking risks within its business and supply chains.

These measures include:

• Assessment of supplier suitability and reputation

• Verification of supplier legitimacy and operational capability

• Review of labour practices where relevant

• Monitoring of higher-risk geographic regions and sectors

• Inclusion of ethical compliance expectations within supplier engagements

• Escalation procedures where concerns are identified

LCI reserves the right to terminate relationships with suppliers or contractors found to be

in breach of ethical or legal obligations relating to modern slavery.

5. Risk Assessment and Risk Management

LCI acknowledges that certain operational activities and international supply chains may

present elevated risks relating to modern slavery and labour exploitation.

Potential risk areas may include:

• Overseas contractor engagement

• Third-party field resource networks

• High-risk jurisdictions identified through international risk indices

• Labour-intensive outsourced services

To manage these risks, LCI:

• Conducts proportionate supplier assessments

• Applies enhanced oversight where higher-risk regions are involved

• Maintains internal approval controls for supplier onboarding

• Reviews operational relationships periodically

• Encourages reporting of concerns through confidential channels

6. Effectiveness and Performance Monitoring

LCI measures the effectiveness of its approach to preventing modern slavery through:

• Ongoing supplier and contractor review processes

• Monitoring of reported concerns or incidents

• Internal management oversight

• Corrective action procedures were required

Performance indicators may include:

• Number of modern slavery concerns identified or escalated

• Completion of staff awareness training

• Supplier compliance monitoring outcomes. At the date of this statement, LCI is not aware of any confirmed incidents of slavery or

human trafficking within its business operations.

7. Reporting Concerns

LCI encourages employees, contractors, suppliers, and stakeholders to report concerns

relating to unethical conduct, labour exploitation, or modern slavery without fear of

retaliation.

Concerns may be raised through management channels or confidential reporting

mechanisms where available.

All concerns are reviewed appropriately and investigated proportionately.

09. Approval and Review

Policy Owner: LC Investigation Management

Policy Name: Modern Slavery & Human Trafficking Policy

Effective Date: 01/2026

Review Date: 01/2027