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Modern Day Slavery

Slavery and human trafficking statement
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps we have taken to ensure that our business as well as our supply chains are free from slavery and human trafficking during the financial year ending 31 December 2018.

Introduction
Lufthansa Technik Landing Gear Services UK is committed to preventing slavery and human trafficking occurring in any of its activities, as well as seeking to ensure our supply chains are also free from such practices.

Our organisational structure and operations
Lufthansa Technik Landing Gear Services UK is a repair and overhaul provider based near Heathrow in London. We employ over 300 people in the UK and are a wholly owned subsidiary of Lufthansa Group. Our parent company has its head office in Germany.

Nature of our supply chains
Our supply chains are complex and products are purchased internationally. Lufthansa Technik Landing Gear Services UK works with more than 450 suppliers. The company insists our suppliers share our fundamental ethics, values and expects a high level of working standards. Wherever possible, it encourages face to face communication between the company and suppliers at all levels of seniority, to ensure risks are fully assessed and due diligence enabled.

All new suppliers to Lufthansa Technik Landing Gear Services UK are subject to a supplier approval process and existing approved suppliers are reassessed every 2 years. Wherever possible visits to supplier factories are arranged in order to audit, assess the conditions of the facilities and carry out checks. These visits may be either announced or unannounced.

With these practices Lufthansa Technik Landing Gear Services UK endeavours to ensure responsible practices by its direct suppliers and so to meet its own standards for corporate responsibility.

Policies relating to slavery and human trafficking
The group has various policies, including Anti-slavery, CSR and Sustainability which reflects our commitment to minimise the risks of human trafficking and other modern slavery practices infiltrating our business operations or supply chains, and to acting ethically and with integrity in all our business activities and relationships.

We endeavour to ensure our suppliers are aware of our policies and take appropriate measures to ensure our suppliers adhere to the same high standards. Our policies have been developed by and in conjunction with our employees and our trade unions.

Risk Assessment
We use various processes and resources to assess which of our own activities and supply chains represent the highest risks in respect of slavery and/or human trafficking.

Due Diligence
In order to monitor and mitigate the risks of slavery and human trafficking occurring within our business and our supply chains we aim to undertake various due diligence processes.

Employee training
We provide and facilitate training to employees to ensure they understand the risks of modern slavery and human trafficking infiltrating our business and/or our supply chains and attempt to effectively operate our policies and procedures to mitigate all known risks.

We have a whistleblowing policy which provides protection to those who whistle-blow in relation to any issue, including modern slavery and human trafficking.

Monitoring
We will use and fully consider key performance indicators (KPI’s) to monitor how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains.

Our policy is a zero-tolerance approach to Modern Slavery. It is vital all our business relationships are conducted ethically, with integrity and transparency. We are committed to implementing and enforcing effective systems and controls to ensure Modern Slavery and Human Trafficking are not taking place anywhere within our business or its supply chains.

Managing Director
27 March 2019

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