Modern Slavery Statement
Modern Slavery Policy
Purpose
This statement is made on behalf of Lowe Corporation and the entities that they own or control
pursuant to section 54(1) of the Modern Slavery Act 2015 (the Act). We are committed to operating
with integrity, responsibility, and respect for human rights across our global operations. Modern
slavery is a heinous crime that takes various forms, including forced labour, human trafficking, and
child labour. This policy outlines our commitment to preventing modern slavery in all its forms and
sets the expectations for our employees, suppliers, and business partners.
Definition
Slavery, child labour and human trafficking are serious crimes and a violation of fundamental human
rights. There are various forms of ‘Modern Slavery’ which deprives victims of their liberty and usually
involves financial exploitation.
We have a zero-tolerance approach to modern slavery and are committed to ensuring that our
operations and supply chains are free from any form of slavery or human trafficking.
Our Commitments:
• Human Rights Due Diligence: We will conduct regular assessments to identify and mitigate
the risk of modern slavery in our operations and vet our supply chains accordingly.
• Supply Chain Transparency: We will strive for transparency in our supply chain by mapping
our suppliers, evaluating their labour practices, and working collaboratively with them to
address any issues identified.
• Supplier Audits and Assessments: We reserve the right to conduct audits and assessments of
our suppliers to ensure compliance with our anti-slavery policy. Suppliers will be expected to
uphold similar standards in their own supply chains.
• Employee Awareness and Training: We are committed to raising awareness among our
employees regarding the risks of modern slavery and providing training to those in roles with
specific responsibilities in supply chain management.
• Reporting Mechanisms: We encourage employees, suppliers, and other business partners to
report any concerns related to modern slavery through established channels, as per the
“Raising a Concern” guidelines below.
Responsibilities:
• Executive Leadership Team: The Executive Leadership Team is responsible for ensuring the
effective implementation and enforcement of this policy.
• Management: All levels of management are responsible for ensuring that their teams are
aware of and comply with this policy.
• Employees: Every employee has a responsibility to report any concerns related to modern
slavery as per the reporting mechanisms outlined above, and to cooperate with the
company's efforts to eliminate it.
• Suppliers and Business Partners: Suppliers and business partners are expected to comply
with this policy and actively work towards ensuring that their operations and supply chains
are free from modern slavery.
Raising a concern
Step 1
Lowe has an open-door policy and encourages people to share their concerns, suggestions or
complaints with their line manager, Talent Team representative, or Head of Legal in the first instance.
This may be done either verbally or in writing.
Step 2
If you are not comfortable speaking with your line manager or other representatives mentioned in
Step 1 or you are not satisfied with your line manager’s response, you are encouraged to report a
concern to a Board Director.
Handling of reported violations
The person who you raise the concern will listen to and consider your concern carefully and
determine whether any action is needed. This may mean reporting it to more senior members of
staff or to the Head of Legal.
Lowe will, to the extent appropriate, inform the reporter of the status of the investigation and in
addition Lowe may require additional assistance or information.
Confidentiality
The Policy encourages individuals to speak up and report potential, suspected or actual violations of
this Policy. Anyone making a report can be reassured that their concerns will be taken seriously and
carefully investigated, and that their confidentiality will be respected.
Any report made under this Policy will be handled promptly, sensitively and seriously and treated as
far as reasonably practicable in a confidential manner. Investigation into the report will be handled
by persons with the appropriate level of seniority and expertise. If confidentiality is not reasonably
practicable, for instance, because of the nature of the information, this will be explained to the
reporter and the Company will seek to address any questions or concerns.
The person making a report is expected to keep confidential the fact that he/she has reported an
alleged breach, the nature of and details associated with the alleged breach, and the identity of all
entities and persons referenced in the report.
The identity of any person against whom a report has been made will also be handled sensitively,
seriously, and confidentially until such time as the report is judged to be well-founded and it is
appropriate for the authorities and/or such person(s) to be notified.
Where the law permits, a report may be made anonymously. However, concerns expressed
anonymously cannot be dealt with as effectively as open disclosures as they are often more difficult
to investigate.
Consequences of Non-Compliance
Non-compliance with this policy may result in disciplinary action, termination of contracts or legal
action, depending on the severity of the violation.