Modern Slavery and Human Trafficking Policy

Modern slavery is a crime and a violation of fundamental human rights. It takes a number of forms, including slavery, servitude, forced or compulsory labour, debt bondage and human trafficking, all of which involve depriving a person of their liberty in order to exploit them for commercial or personal gain.

Lead Conneqt Limited publishes this policy voluntarily, as a matter of good practice and because our clients are entitled to know where we stand. We do not claim that we meet the turnover threshold in section 54 of the Modern Slavery Act 2015, nor that we are required to publish a statement under it. We have adopted this policy because the standard it sets is the right one regardless of size.

The purpose of this policy is to state our position clearly, to set out what we expect of the people and organisations we work with, and to make it straightforward for anyone to raise a concern with us.

This policy applies to everyone who works for or on behalf of Lead Conneqt Limited, in any capacity, and it informs how we select and manage the organisations we buy from and work with.

• Directors and anyone employed or engaged directly by Lead Conneqt Limited
• Contractors, consultants, agency workers and other people engaged to deliver our services
• Suppliers of goods and services to Lead Conneqt Limited, including software and professional services providers
• Any other third party acting for or on behalf of Lead Conneqt Limited

The policy covers our own operations and the parts of our supply chain over which we have influence. It does not create contractual rights for third parties. The expectations set out below are the standard we apply when we select suppliers and, where we set the terms, when we contract.

Lead Conneqt Limited provides a managed outsourced sales development and outbound function to business clients: ideal customer profile development, prospect research, data preparation, cold email, LinkedIn outreach, human telemarketing, reply handling, qualification and appointment setting. We are based in the United Kingdom and our work is business to business.

We want to be honest about risk rather than overstate the assurance we can give. Our direct supply chain consists mainly of software and technology subscriptions, professional services, and the people who carry out research and outreach work for us. We consider the risk of modern slavery within that direct supply chain to be low relative to sectors such as manufacturing, agriculture, construction and logistics, because we do not manufacture goods, we do not hold physical stock and we do not use seasonal or low skilled manual labour.

We recognise that a low assessed risk is not the same as no risk, that risk can sit further down a supply chain than we can see, and that our own risk profile will change as the company grows. We will keep this position under review as our business, our services and our supply chain develop, and we will strengthen our approach where the facts warrant it.

Lead Conneqt Limited has zero tolerance for modern slavery and human trafficking. We commit to the following.

• We do not use, and will not knowingly permit anyone acting for us to use, slavery, servitude, forced or compulsory labour, child labour, debt bondage or human trafficking in any part of our business.
• We do not tolerate exploitative labour practices, including the withholding of wages or identity documents, unlawful deductions, recruitment fees charged to workers, coerced overtime, threats, intimidation or restrictions on a person's freedom of movement.
• Everyone who works for us or is engaged by us must do so freely, must be free to leave, and must be paid at least the legal minimum that applies to them.
• We act lawfully in relation to the right to work, and we do not engage anyone we believe to be working under coercion or without the right to do so.
• We take reasonable and proportionate steps to satisfy ourselves that our suppliers and contractors share these standards, and we ask questions where something does not look right.
• We do not put commercial pressure on a supplier, in price or in deadline, in a way that we know or ought reasonably to know would drive exploitative working conditions.
• We report suspected modern slavery to the appropriate authorities, and we cooperate with any competent authority investigating it.
• We keep this policy and our practices under review as the company and its supply chain grow.

We expect every supplier, contractor and other party in our supply chain to meet the same standard we set for ourselves, and to hold their own suppliers to it. In particular, we require that they:

• comply with the Modern Slavery Act 2015 and all other applicable law on labour rights, working conditions, pay and the right to work;
• do not use slavery, servitude, forced or compulsory labour, child labour or trafficked labour, whether directly or through any subcontractor or labour provider;
• ensure that all work is freely chosen, that workers are free to leave, and that no worker pays a fee to obtain work;
• respond openly and promptly to reasonable enquiries from us about their labour practices and their own supply chain; and
• tell us without delay if they become aware of modern slavery in their operations or supply chain that relates in any way to work carried out for Lead Conneqt Limited.

Where a serious violation is found, or where a supplier or contractor will not cooperate with reasonable enquiries, we reserve the right to suspend or terminate the relationship. We will normally prefer remediation where a supplier engages with us in good faith and the people affected are better served by the relationship continuing on corrected terms, because ending a contract abruptly can leave workers worse off. That preference does not limit our right to terminate.

The Managing Director owns this policy and is accountable for it, including decisions about supplier relationships where a concern is raised.

• The Managing Director approves this policy, reviews it, and decides what action to take when a concern is reported.
• Anyone who buys goods or services on behalf of Lead Conneqt Limited is responsible for applying the expectations in this policy when selecting and managing suppliers.
• Everyone who works for or on behalf of Lead Conneqt Limited is responsible for reading this policy, working consistently with it, and reporting anything that gives rise to concern.
• Suppliers and contractors are responsible for their own compliance and for the conduct of anyone they engage to do work connected to Lead Conneqt Limited.

Failing to report a suspicion of modern slavery is itself a serious matter. If you are unsure whether something amounts to a concern, raise it anyway and let us look at it.

Anyone can raise a concern under this policy, whether they work for us, work for a supplier, or have no connection to us at all. Concerns should be sent to dane@leadconneqt.com or in writing to Lead Conneqt Limited at its registered office, 5 Syston Road, Queniborough, Leicester, LE7 3FX, United Kingdom.

Concerns raised under this policy are taken seriously and are handled confidentially so far as is reasonably possible. You may report anonymously if you prefer, and we will still look into what you tell us, although anonymity may limit how far we can investigate or come back to you.

We will not subject anyone who raises a concern in good faith to detriment or retaliation, including where the concern later turns out to be mistaken. That applies to our own people, to people working for our suppliers and contractors, and to anyone else who comes forward, and we will not accept retaliation by a supplier or contractor against someone who has raised a concern with us.

If you believe someone is in immediate danger, contact the police on 999. Concerns can also be reported independently to the police or to the national modern slavery helpline.

A breach of this policy is treated as a serious matter. Where someone working for or on behalf of Lead Conneqt Limited breaches this policy, we may end their employment or engagement. Where a supplier or contractor breaches it, or will not cooperate with reasonable enquiries, we may require corrective action, suspend work, or terminate the relationship.

Where we find or reasonably suspect modern slavery or human trafficking, we will report it to the appropriate authorities and cooperate with them. Where people have been harmed, our first concern is their safety and welfare rather than the commercial consequences for us.

This policy is owned by the Managing Director and is reviewed at least annually, or sooner on a material change to the business, its services, its supply chain or the law. The current version is always the one published on this page.