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Modern Slavery Policy

Unless stated explicitly in relation to a particular aspect, this policy applies to all activities delivered by the Lucion Group Limited companies which include Lucion Services Ltd, Lucion Delta-Simons Ltd, Lucion Radiation Protection Services Ltd, Lucion Ground Engineering Ltd, Lucion Survey Ltd, Lucion Survey (Landform) Ltd. The Lucion Group companies operate an integrated management system for all policies and procedures in line with our certifications and accreditations, offering a streamlined service to our clients.

1.0 Purpose

This statement sets out Lucion’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains and maintain accordance with the UK Modern slavery Act.

As part of the environmental consultancy sector, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

Lucion takes a zero tolerance towards slavery and human trafficking in its corporate activities, and is absolutely committed to ensuring that its supply chains are free from slavery and human trafficking.

2.0 Scope

This statement covers the activities of Lucion Group Ltd and its companies.

The organisations currently operates in the United Kingdom and internationally.

Lucion will assess whether or not particular activities or countries are high risk in relation to slavery or human trafficking by conducting a risk assessment in relation to the countries operations, slavery and human trafficking as part of a due diligence exercise.

High-risk activities

Currently Lucion does not consider themselves to have any high risk activities.


Responsibility for the organisation’s anti-slavery initiatives is as follows:

  • Policies: The HR department is responsible for putting in place and reviewing policies and the process by which they were developed.
  • Risk assessments: The Compliance and HR departments are responsible for conducting human rights and modern slavery risk analysis.
  • Investigations/due diligence: The Compliance and HR departments are responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking. 

3.0 Relevant Policies

Lucion operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations :

  • Whistleblowing policy: The organisation encourages all its workers, customers and other 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. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
  • Supplier/Procurement code of conduct: The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship.
  • Recruitment/Agency workers: The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

4.0 Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:

  • evaluating the modern slavery and human trafficking risks of each new supplier;
  • conducting supplier audits or assessments which will include analysing the nature of relationships with suppliers and the complexity of supply chains to reduce the risk of slavery or trafficking occurring

5.0 Measures

Lucion will continue to develop its commitment to combat modern slavery and will provide staff training where appropriate.  Lucion will take appropriate action where breaches of this policy by any individuals or organisations working for or on our behalf (including the supply chain) occur.

Ross Boulton
Chief Technical Officer

11th June 2024


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