Modern Slavery Policy

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) 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.

The Lowe Group – Modern Slavery Policy
Created by: The Talent Team
Last Reviewed: December 2023

Raising a concern
Step 1
Lowe has an open-door policy door policy and encourages people to share their concerns, suggestions or 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 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.

The Lowe Group – Modern Slavery Policy
Created by: The Talent Team
Last Reviewed: December 2023