Lotter London Modern Slavery Statement

Lotter London is committed to preventing all forms of modern slavery and forced labour throughout our operations and supply chains. This modern slavery statement explains our approach to tackling human trafficking, slave labour and other exploitative practices, and sets out the steps we take to ensure that our values are reflected across every tier of suppliers and contractors.

We operate a strict zero-tolerance policy on slavery and human trafficking. Our anti-slavery and anti-human trafficking stance is embedded in our corporate code of conduct and enforced through contractual obligations. All staff, partners and vendors are expected to understand and comply with our anti-slavery policy, which explicitly rejects any form of exploitation, including bonded labour and deceptive recruitment.

As part of our supply chain vigilance, Lotter London conducts targeted supplier audits and risk assessments. We prioritise audits for high-risk categories and geographies, using a combination of desk-based due diligence and on-site inspections where appropriate. Supplier monitoring covers wage practices, working hours, freedom of movement, and valid employment contracts to guard against any indicators of human trafficking or forced work.

Due Diligence, Supplier Audits and Remediation

We maintain a robust programme of supplier due diligence that includes pre-engagement screening and periodic reassessment. Our procurement teams require suppliers to demonstrate compliance through documentation, third-party certifications and direct engagement. Where issues are identified, we implement corrective action plans and follow-up audits until satisfactory remediation is achieved.

Supplier audits form a core element of our preventive work. Audits are risk-based and include random checks, worker interviews and review of payroll records. We work with independent auditors and industry bodies to corroborate findings and ensure transparent reporting. If exploitative practices are discovered, we take immediate action which may include suspension or termination of contracts and support for affected workers.

We also provide training and resources for suppliers to help them meet our standards. This includes guidance on recognising indicators of modern slavery, improving HR systems, and establishing fair recruitment practices. Our aim is both to prevent abuses and to build supplier capacity for sustainable compliance.

Reporting Channels, Accountability and Annual Review

Lotter London promotes multiple confidential reporting channels so that workers, suppliers and third parties can raise concerns without fear of retaliation. We operate an internal whistleblowing mechanism, anonymous reporting options and a clear escalation path for serious incidents. Reports are handled promptly, investigated thoroughly and treated with strict confidentiality.

To ensure accountability, senior leadership and the board receive regular updates on slavery and trafficking risks, audit outcomes and remediation progress. Key performance indicators are tracked and published internally to monitor our continuous improvement. Our procurement and compliance teams are responsible for implementing corrective measures and ensuring supplier adherence to our standards.

We conduct an annual review of this modern slavery policy and our anti-slavery programme to evaluate effectiveness and adapt to emerging risks. The annual review includes an assessment of supply chain changes, audit results, training completion rates and any incidents reported. Based on this review we update our procedures, increase focus where necessary, and allocate resources to strengthen preventive measures.

In summary, Lotter London’s commitment to combating slavery and human trafficking is built on clear policies, regular supplier audits, accessible reporting channels and an ongoing cycle of review and improvement. We see this as a continuous responsibility and pledge to keep evolving our approach to eradicate modern slavery from our business relationships.

Key elements of our approach include:

• Zero-tolerance policy publicly endorsed by senior management;
• Systematic supplier audits and targeted due diligence;
• Multiple confidential reporting channels and protective measures for whistleblowers;
• Annual review and continuous improvement of policies and processes.

We will continue to work collaboratively with suppliers, industry peers and independent experts to strengthen detection, prevention and remediation of forced labour, bonded work and human trafficking in every part of our supply chain.