At Lothian Broadband Networks Limited (LBN) we are committed to protecting and respecting human rights. We believe that everyone everywhere is entitled to basic rights and freedoms. That’s why we have a zero-tolerance approach to modern slavery in all its forms: human trafficking, slavery, child labour, servitude and forced or compulsory labour.

We are committed to acting ethically and with integrity in all of our business relationships. Modern Slavery practices have no place in our operations, and we expect the companies and people who work with us and on our behalf to take a similar stance, wherever they are in the world.

We strive to incorporate respect for human rights into our employment practices and values. No one should be made to work against their will, deprived of their identity papers or have to pay to work with us. We only work with people who choose to work freely. We respect the right to equal opportunity, freedom of association and collective bargaining.

This statement is made in compliance with the duties set out in the Modern Slavery Act 2015. We also expect our suppliers and their supply chains to comply with this legislation, as well as all other relevant legislation and regulations in the countries in which they operate.

Supply Chain Risks

LBN are committed to ensuring modern slavery does not take place in our own business or supply chain. Our Finance & Business Operations Team have been given the responsibility to comply with Modern Slavery Act obligations as well as identifying and dealing with any modern slavery risks that may exist in our supply chains.

The risk of modern slavery within our own operations is low, as all of our employees are based in the UK. All of our employees are salaried and paid at or above the Living Wage. Right to work checks are completed in accordance with relevant government instruction. All of our terms and conditions, as detailed in the employment contract, adhere, as a minimum, to the statutory labour laws that are in place at the time.

The majority of our recruitment is carried out directly and in occasions where this is carried out by a third party, we require them to adhere to the Modern Slavery Act.

We recognise that the risks of modern slavery may be higher in our supply chains. We aim to do everything we can to eliminate the risk of modern slavery occurring in our business and supply chains. We carry out the following actions to enable this:

Cancel our contract with any supplier who demonstrates non-compliance with our policy and the Modern Slavery Act

1. Use simple risk factors regarding the supplied, such as type of product or service, country of origin or workers’ skill level, to determine the modern slavery risk of our direct supplier
2. Visit sites of higher risk suppliers to better understanding the reality of working conditions
3. Work with higher risk suppliers to establish an improvement plan which is monitored closely by our Finance & Business Operations team

LBN are dedicated to doing more to prevent the risks of modern slavery in our supply chain relationships, and will look to establish the following in 2022:

1. Map our supply chain to assess where any extreme risk factors lie
2. a Supplier Code of Conduct that is included in our procurement and supplier contracting process
3. Include a section in our Staff Handbook about the Modern Slavery Act