In accordance with the Modern Slavery Act 2015 (Act), LSL Property Services plc (LSL) published this Statement on behalf of itself and its subsidiary e.surv Limited (e.surv) which is included within the scope of the Act.
This Statement sets out the controls relevant to members of the LSL group of companies (LSL Group) with a focus on the steps that have been taken during the financial year ending 31 December 2023 to prevent modern slavery and human trafficking from occurring within the businesses and supply chains.
This Statement replaces LSL’s last statement which was published in May 2023 (in respect of financial year ending 31 December 2022).
Introduction
LSL recognises the continued existence of slavery and human trafficking in society, the significance of its impact on its victims and the wider society and the part organisations play in eradicating it from society and the businesses like the LSL Group.
The LSL Group is a leading provider of financial services, surveying and valuation and estate agency franchising services. The LSL Group provides services to mortgage intermediaries and estate agency franchisees, and valuation services to many of the UK’s largest lenders. Details of the LSL Group’s business model are included in the Purpose, Strategy, Culture, Values and Business Model section of LSL’s Annual Report and Accounts 2023, which can be found at www.lslps.co.uk.
The LSL Group operates three Divisions:
At the date of this Statement:
Financial Services provide compliance and other services to members of LSL’s Financial Services Network, which includes the PRIMIS Mortgage Network1 and The Mortgage Alliance (TMA)2. The Financial Services Network is one of the UK’s largest mortgage and insurance networks.
Surveying & Valuation includes e.surv, which also trades as Walker Fraser Steele in Scotland. It provides surveying and valuation services to many of the largest lenders in the UK. The Division also includes the asset management businesses – LSL Corporate Client Department (trading name of LSL Corporate Client Services Limited) and
Templeton LPA Limited, who specialise in managing the sale of residential properties on behalf of corporate clients and property investors.
Estate Agency Franchising provides services including brand marketing, commercial and IT support to a network of 300+ territories across the UK. These territories are independently managed and operated by Estate Agency franchisees under a range of brands including Your Move and Reeds Rains.
The LSL Group also includes specialist businesses which support Estate Agency franchisees with related products and services:
The LSL Group creates employment opportunities directly and indirectly via supply chains. Human rights and modern slavery are at the core of the LSL Group’s commitment to doing the right thing. LSL is committed to promoting the highest standards of integrity, personal conduct, ethics and fairness, in line with the UK regulatory environment it operates in.
LSL has previously identified supply chains as the greatest area of risk and exposure to modern slavery within the LSL Group. With the significant changes to parts of the LSL Group’s business model that occurred during 2023, LSL recognises the need to revisit the Group’s modern slavery risk assessment in light of the new structure. The LSL Group has recently created a Group Chief Risk Officer (Group CRO) role and this role will be operational from July 2024. The CRO will be responsible for the development of the Group Risk Framework including a review of modern slavery risks.
The Divisions have in place established and direct relationships with a number of primarily UK-based suppliers who deliver a variety of services including professional services3, utilities and telecoms, and facilities management.
As part of service delivery, the Divisions will procure services. This could be for themselves, to benefit their own customers or those of other LSL Group companies (including property management services and contractors).
Within the LSL Group steps are taken to assess and manage the risk of slavery and human trafficking taking place.
LSL expects its supply chain to adhere to international standards on human rights, including with respect to child and forced labour, land rights and freedom of association. e.surv undertake a risk assessment as part of its supplier due diligence processes, which includes modern slavery and human trafficking.
During 2024 the Surveying & Valuation Division has committed to reviewing its approach with a view to sharing areas of best practice to further develop supplier management across the LSL Group. As part of this it is engaging with suppliers to significantly enhance KPI’s and the method through which LSL Group companies conduct supplier due diligence and risk assessment.
LSL protects and promotes the human rights of colleagues in the following ways:
The prevention of modern slavery and human trafficking is included within the LSL Group Combined Ethics Policy (Policy). The Policy includes the whistleblowing policy and sits alongside the LSL Group’s speak up policy. The Policy sets out responsibilities and provides information and guidance on the identification and escalation of matters relevant to the prevention of modern slavery and human trafficking. The Policy is reviewed on a tri-annual basis with reviews undertaken more frequently where required, and it applies to all LSL Group colleagues. A summary of the Policy is available at www.lslps.co.uk.
LSL Group companies continue to strive to raise awareness and ensure colleagues are equipped to identify and report potential incidences of modern slavery or human trafficking.
During 2023, the LSL Group HR team continued to create and deliver in-house training to all colleagues, focussed on preventing and identifying modern slavery and human trafficking.
Previous risks assessments have identified specific roles at increased risk of exposure and following a review in 2023, colleagues training and guidance was updated and delivered.
All LSL Group colleagues are made aware of the requirements under the Act and how to identify and report issues of modern slavery and human trafficking through the Policy. During 2023, e.surv colleagues made six reports setting out modern slavery concerns to an external body, and it will continue to take steps to ensure its colleagues have the confidence and awareness to identify vulnerabilities.
Set out below is a summary of the LSL Group’s performance (including e.surv’s) against the KPIs set out in the Statement relating to 2022. By their nature they are qualitative and, as addressed below, consideration is being given as to how to engage with suppliers to help to significantly enhance these and the method through which supplier due diligence and risk assessment is conducted:
KPI from the 2022 Statement:
Progress was impacted by the LSL Group restructure that took place during 2023. These commitments remain relevant and will be progressed during 2024. The appointment of the Group CRO will enable the progression of the work on the KPI’s.
This Statement has been published on behalf of LSL and e.surv and has been approved on behalf of the LSL Board Group by the Group CEO on 28 June 2024.
Signed by:
David Stewart, Group Chief Executive Officer
LSL Property Services plc