Modern Slavery & Human Trafficking Statement

INTRODUCTION
This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 31 July 2021.

Lowe Management Ltd (‘the Company’, ‘we’, ‘us’ or ‘our’) is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values.

ORGANISATIONAL STRUCTURE
Lowe Management Ltd has business operations in the United Kingdom.

We operate in the real estate sector. The nature of our supply chains is as follows: We work with a number of key direct suppliers, who provide us with goods, such as building materials, and services, such as outsourced contractors and marketing services. For more information about the Company, please visit our website: www.thelowegroupltd.com.

POLICIES
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner.

These include the following:

• Recruitment and selection policy – We conduct checks on all prospective employees to verify that they are eligible to work in the UK. Certain roles require a Disclosure and Barring Service (DBS) check where employees may be working with vulnerable people.
• Supplier code of conduct – We operate this policy to ensure our suppliers operate in full compliance with the laws, rules and regulations of the countries in which they
  operate, and to seek similar commitments across their own supply chain.
• Whistleblowing policy – We operate this policy so that employees are able to raise concerns about how staff are being treated or practices within our business or our
  supply chains without fear of reprisal.
• Staff code of conduct – We are committed to the fair treatment of all staff. Our staff code of conduct reflects our core values and expected behaviours. The code of conduct makes it clear that we have a zero-tolerance approach to modern slavery.
• Procurement policy – We want to make sure that potential suppliers are committed to ensuring that slavery and human trafficking is not taking place within their own supply chains. Our procurement policy and supporting procedures set out controls and checks undertaken to help verify this.
• Safeguarding policy – This policy highlights the potential risks of modern slavery and human trafficking, including how to identify signs of exploitation and how to report concerns.

We make sure our suppliers are aware of our policies and adhere to the same standards.

DUE DILIGENCE
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:

• Internal supplier audits.

Our due diligence procedures aim to:

• Identify and action potential risks in our business and supply chains.
• Monitor potential risks in our business and supply chains
• Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
• Provide protection for whistleblowers.

RISK AND COMPLIANCE
The Company has evaluated the nature and extent of its exposure to the risk of slavery and
human trafficking occurring in its UK supply chain through:

• Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping.

We do not consider that we operate in a high-risk environment because The business operates in this risk level environment because the majority of our supply chain is based in the UK and in low-risk industries.

We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will seek to terminate our relationship with that supplier immediately.

EFFECTIVENESS
The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPIs are carried out in the form of regular audits of suppliers.

The statement was approved by the board of directors.

Tim Lowe, Director
Lowe Management Ltd