Modern Day Slavery Policy

1. Structure, business and supply chain

Loxton Young is a service provider for European and Overseas trained nurses.

We are unique in the services offered to all our clients. These range from hospitals, walk-in centres, care home groups as well as individual nurses globally.

In the last 4 years Loxton Young were involved in a number of Recruitment Events globally. During the course of these events we became the service provider to many recruiters in the UK and overseas. This specialist transition came due to our Directors identifying a need for bespoke services for retaining nurses, during their professional registration process within the global healthcare sector.

We are serious about our brand because it’s part of our identity and so is our commitment to corporate social responsibility. We believe transparency is the best way we can ensure the public that we are doing our best as an ethical corporate citizen. In that spirit, we have published our annual statement for slavery and human trafficking, made in compliance with section 54 of the Modern Slavery Act 2015, in which we explain how slavery and human trafficking can affect our business and the steps we are taking in the fight against it. This slavery and human trafficking statement also addresses the steps taken by Loxton Young Ltd. This statement is intended to fulfil the legal requirement for a slavery and human trafficking statement. Our efforts against slavery and human trafficking complement our broader CSR Policy and our adoption of the Ethical Trading Initiative.

Loxton Young Ltd is headquartered in London, United Kingdom and provides services globally, including the United Kingdom.

Building on our existing CSR Policy and our commitment to the Ethical Trading Initiative, we have embraced the requirement to publish a slavery and human trafficking statement. This will allow us to share our efforts against slavery and human trafficking and improve and measure our success each financial year. This past financial year ending 31 March 2019, we took the following key steps to ensure slavery and human trafficking did not occur within our organisation or supply chain.

2. Slavery and human trafficking policies

Notably, we developed our Slavery and Human Trafficking Policy, which can be found within our CSR Policy. We also updated our Supplier Code of Conduct. It sets out clear objectives for 1, 3 and 5 year slavery and human trafficking plans around the following themes:

• Relationships: Strengthening our supplier engagement process

• Feedback: Establishing grievance mechanisms and channels for individual worker feedback

• Knowledge: Improving our knowledge base by collecting relevant data and improving service delivery

• Third party engagement: Building strategic alliances with independent social auditors, unions and NGOs

• Measurable change: Developing verifiable KPIs to measure progress

• Supplier collaboration: Encouraging suppliers to collaborate to address slavery and human trafficking issues

• Incentivisation: Developing mechanisms to incentivise employees and suppliers to address slavery and human trafficking and improve labour standards

• Accountability: Establishing a framework for organisation accountability to allow for raising issues, making suggestions, voicing grievances and reporting slavery and human trafficking

2. Due diligence procedures

We understand that our biggest exposure to Modern Slavery is in our product supply chains, where we have undertaken activity over the last 4 years to minimise the risk of Modern Slavery. Within these areas, new suppliers are subject to due diligence checks in the form of ethical/compliance audits. Such audits are also regularly conducted for existing suppliers. These audits assess compliance with the Global Sourcing Principles and are, amongst other things, intended to identify any Modern Slavery practices. If issues are identified, appropriate investigative and remedial actions will be taken.

4. Identifying, assessing and managing risk

We set out to identify the extent of any slavery and human trafficking in our supply chains by instituting an annual review questionnaire for existing suppliers to understand suppliers’ self-assessment of slavery and human trafficking issues, allowing us to better identify slavery and human trafficking issues as they develop over time and to collect supplier-provided data to track improvement in suppliers’ attitudes.

5. Key performance indicators

In order to assess the effectiveness of our modern slavery measures we will be reviewing the following key performance indicators:

• Staff training levels

• Number of slavery incidents reported in the supply chain

6. Training available to staff

A key part of our slavery and human trafficking strategy is to promote cultural change through training. This last financial year we:

• Delivered online training modules on modern slavery to all staff

• Ran 2 training seminars for our suppliers’ at our offices in Mumbai