Modern Slavery & Human Trafficking Statement

LCC has a zero-tolerance approach to modern slavery and human trafficking, in our own business and across our supply chain.

Policy owner: Moein Memari, Managing Director · Policy date: 25 September 2026 · Ref: LCC-MSL-POL-004 · Review: annually. LCC's turnover is below the £36 million threshold for a mandatory statement under Section 54 of the Modern Slavery Act 2015. We publish this voluntarily and apply the principles of the Act to our business and supply chain.

Our position

We are committed to acting ethically and with integrity in all our business relationships. Construction is recognised as a high-risk sector for modern slavery, particularly through labour supply chains, labour-only subcontracting and materials sourced from overseas, so we put specific checks in place to manage these risks.

This policy applies to all LCC directors, employees, agency workers and trainees, and to all subcontractors, labour providers, suppliers and consultants working for or on behalf of LCC.

Our commitments

Right-to-work checks on all employees before they start work.
All workers paid at least the National Minimum Wage or National Living Wage, directly into their own bank account, with clear payslips.
No recruitment fees charged to workers, and no deductions that take pay below legal minimums.
We never hold workers' passports, identity documents or bank cards.
Written terms of employment in a language each worker understands, with freedom to leave on reasonable notice.
The same standards required of our subcontractors, labour providers and suppliers.

Risks and how we control them

Risk area	How LCC controls it
Labour-only subcontractors	Pre-qualification checks, right-to-work confirmation, CSCS card checks at induction and site monitoring.
Agency and temporary labour	Established, reputable agencies only, with written confirmation that no fees are charged to workers.
Materials from overseas	Purchasing mainly through established UK merchants, preferring suppliers with responsible sourcing credentials.
Cleaning, security and waste services	Checks on providers' employment practices and pay rates.
Third-party accommodation or transport	Checks where workers arrive in groups or appear to be housed by an employer.

Supply chain due diligence

New subcontractors and labour providers complete our pre-qualification, confirming Modern Slavery Act compliance, right-to-work checks and payment practices.
Subcontract orders and supplier terms require compliance with this policy and allow LCC to check it.
Higher-risk packages, such as labour-only work, receive additional checks, including sample payroll and right-to-work checks where appropriate.
We will stop working with any supplier or subcontractor found to be involved in modern slavery.

Training and reporting concerns

Modern slavery awareness is part of our inductions and toolbox talks, and Site Managers and staff involved in buying are trained to recognise the signs.

Anyone who suspects modern slavery in our business or supply chain should report it to our Managing Director. Concerns are treated confidentially, and no one raising a genuine concern will suffer any detriment.

If someone is in immediate danger, call 999.
Modern Slavery and Exploitation Helpline: 08000 121 700.
Police non-emergency: 101.

Breaches and review

Employees who breach this policy face disciplinary action, which may include dismissal. We will end our relationship with any subcontractor or supplier found in breach and report suspected offences to the authorities. The Managing Director reviews this policy, our supply chain risks and any concerns raised at least once a year.