Modern Slavery Statement – LSA Recruit

LSA Recruit is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps we have taken to prevent modern slavery and human trafficking within our operations and supply chains.

As a “People First” organisation with over 18 years of experience in the recruitment and IT staffing industry, we recognise our responsibility to be alert to the risks, however small, in our business and the wider supply chain. We are committed to acting ethically and with integrity in all our business dealings.

LSA Recruit (www.lsarecruit.co.uk) provides recruitment and IT services, including recruitment, IT training, and cybersecurity consulting. Our operations include:

• Recruitment Services: Permanent, Contract, Contract-to-Hire, Executive Recruitment, and Offshore Recruitment.
• Specialised Placement Areas: Business Intelligence, Artificial Intelligence, Data Science, SalesForce, SAP, Java Developer, Business Analyst, Data Architect, Automation Consultant, Cloud Analyst, IT support, and IT contract jobs.
• Training Services: LSA Training, providing professional certifications and IT skills development.
• Cybersecurity Consulting: Security assessment & strategy, threat monitoring & incident response, and compliance & governance support.

We operate in the UK and support clients and candidates internationally (including through our offshore recruitment services). Our organisational structure comprises leadership, recruitment and account management teams, training delivery and operations, and cybersecurity consulting functions. We recognise that recruitment activities and the use of third parties can present heightened vulnerability risks for individuals, so we apply appropriate safeguards and oversight.

Our supply chain and business relationships include:

• Clients and end-hirers who engage us for recruitment and IT services (including contract and offshore recruitment).
• Candidates and talent networks for placement with clients (both domestic and international).
• Offshore partners and any third parties supporting sourcing, screening, onboarding, and payroll/engagement administration.
• Training and consulting suppliers, including trainers/associates and providers of learning platforms, content, and certification partners.
• Technology suppliers for IT infrastructure, software, background checking, and cybersecurity tools.
• Professional services such as legal, accounting, and compliance support.
• Office and facilities suppliers and equipment providers.

We recognise that, while our industry is generally lower risk than sectors such as agriculture or manufacturing, modern slavery risks can arise in recruitment supply chains (particularly where workers are sourced internationally or via third parties). We maintain vigilance across all relationships.

LSA Recruit is committed to preventing modern slavery and human trafficking in our operations and business relationships. We support the aims of the Modern Slavery Act 2015 and are committed to acting ethically and with integrity, implementing and enforcing effective systems and controls to ensure modern slavery is not taking place.

We have a zero-tolerance approach to modern slavery and human trafficking. We expect the same standards from our clients, suppliers, partners, and any other parties we engage with, and we will take appropriate action (which may include terminating relationships) where we identify non-compliance or unacceptable risk.

As part of our approach to identifying and mitigating risks of modern slavery and human trafficking, we apply proportionate due diligence and onboarding processes. These include:

• Client due diligence: We undertake checks proportionate to the engagement, which may include verifying client identity and legitimacy, confirming the nature of roles and working arrangements, and assessing whether working practices raise red flags (e.g., indicators of exploitation, unlawful deductions, restriction of movement, or confiscation of documents).
• Supplier and partner due diligence: We assess suppliers and offshore partners based on risk, including reputational checks, confirmation of relevant policies and controls (such as anti-slavery, whistleblowing, and ethical labour practices), and contractual commitments to comply with applicable laws and standards.
• Candidate safeguards: We verify identity and (where applicable) right to work/eligibility checks, maintain clear and transparent communications about role requirements and pay, and we do not charge candidates fees for placement.
• Contractual controls: Where appropriate, we include terms requiring compliance with the Modern Slavery Act 2015 and applicable employment and labour laws, and we reserve rights to audit, request information, or take remedial action.
• Ongoing monitoring: We maintain open communication channels with clients and candidates and review concerns or complaints promptly, escalating where needed.

LSA Recruit assesses modern slavery risk with reference to factors including:

• Geographic and jurisdictional risks (particularly where offshore recruitment is used).
• Use of third parties in sourcing, onboarding, or administration.
• Role type and candidate vulnerability (e.g., workers who are new to the UK, dependent on third parties for accommodation/transport, or facing language barriers).
• Payment and engagement practices, including transparency of pay and deductions.

In our IT recruitment, training, and cybersecurity consulting activities, we consider the inherent risk of modern slavery to be generally low. However, we maintain vigilance and apply enhanced controls where risk may be elevated, including in offshore recruitment, international supply chains, or where third parties are involved. Where risks are identified, we take steps to mitigate them, which may include enhanced due diligence, additional contractual safeguards, increased monitoring, or discontinuing relationships.

To ensure our teams understand how to identify and respond to modern slavery risks, we provide training and awareness initiatives, particularly for staff involved in recruitment, client management, and procurement. Training covers:

• Common indicators of modern slavery and human trafficking (including debt bondage, coercion, restricted freedom, threats, and document retention).
• How to spot red flags in recruitment processes and client engagements (including excessive recruitment fees, misleading job information, or pressure tactics).
• How to raise concerns and how we escalate and respond to reports.
• Expectations on ethical conduct, transparency, and fair treatment of candidates.

Training is refreshed periodically and reinforced through guidance and internal communications.

We encourage anyone who has concerns about modern slavery or human trafficking connected to our business or supply chains to speak up. Concerns can be raised:

• Internally to a line manager or senior leadership; and/or
• Via our whistleblowing arrangements (where applicable).

Reports can be made confidentially and will be treated seriously, assessed promptly, and escalated appropriately. We will not tolerate retaliation against anyone who raises a concern in good faith.

Where appropriate, we may refer matters to relevant authorities or specialist organisations, and we will cooperate with any investigations. If you believe someone is in immediate danger, contact emergency services.

We operate several internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

• Anti-Slavery Policy: This statement outlines our stance against modern slavery.
• Whistleblowing Policy: We encourage all employees, candidates, and business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.
• Recruitment Policy: We operate a robust recruitment policy, including conducting “right to work” checks for all candidates to safeguard against human trafficking or individuals being forced to work against their will.
• Code of Conduct: We maintain high standards of professional conduct and expect our employees and contractors to adhere to ethical principles in all dealings.

As part of our initiative to identify and mitigate risk, we:

• Verify the identity and eligibility to work of every candidate we place, whether for permanent or contract roles.
• Perform enhanced due diligence when engaging with offshore partners and international talent pools.
• Ensure that we do not charge candidates placement fees, which is a key indicator of potential exploitation.
• Review our suppliers to ensure they have their own modern slavery statements or equivalent ethical policies where applicable.
• Maintain open communication with clients and candidates to ensure fair treatment and compliance with labour laws.

LSA Recruit assesses the risk of modern slavery based on:

• The country of origin for offshore recruitment.
• The nature of the services provided.
• The vulnerability of the candidate demographic.

In our Cybersecurity and IT Training divisions, the risk is considered low; however, we remain vigilant across all business units. In our offshore recruitment services, we implement stricter vetting procedures to ensure compliance with both UK standards and local labour laws.

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide relevant training to our staff, particularly those involved in recruitment and procurement. This training covers:

• How to identify the signs of slavery and human trafficking.
• What initial steps should be taken if modern slavery is suspected.
• How to escalate reports of modern slavery within the organisation.

We use the following KPIs to measure how effective we have been in ensuring that slavery and human trafficking are not taking place in any part of our business or supply chains:

• Completion of right-to-work and identity verification for 100% of candidates placed.
• Annual review of offshore recruitment partner agreements.
• Monitoring of whistleblowing reports related to labour standards.

This statement has been approved by the leadership of LSA Recruit and will be reviewed and updated annually.

Gopal Mekala CEO, LSA Recruit Date: 10 March 2026