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Modern Slavery Statement

This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 (as amended 2024) and in accordance with Directive (EU) 2024/1760 on Corporate Sustainability Due Diligence (CSDDD).

Applicable legislation for the LRC Group includes;

  • European Union; Directive (EU) 2024/1760 (CSDDD) and related due-diligence obligations.
  • the Criminal Law (Human Trafficking) Acts 2008–2024 and the National Referral Mechanism Act 2023 in Ireland.
  • In the UK it is the Modern Slavery Act 2015, as amended by the Modern Slavery (Amendment) Bill 2024 and article 4(1) (Schedule 1) of the Human Rights Act.
  • Articles 1, 2, 11, 12 and 12a of the Basic Law for the Federal Republic of Germany (amendments through 2014), sections 232, 233, 234, 236, 237, 239 & 240 of the German Criminal Code, sections 7 & 8 of chapter 1 of Act to Introduce the Codes of Crimes against International Law (2002) and the Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz, 2023).
  • There is no legislation in place in Poland, which prohibits slavery, although article 31 of the Constitution guarantees protection of the freedom of the person and deprivation of liberty is criminalised under article 189 of the Criminal Code. Slavery may also form an element of an offence of trafficking under articles 115(22) and 189A of the Criminal Code. In addition, various sections of the Polish Labour Code and Offences Against the Rights of Persons Pursuing Paid Work Act.
  • The main legal framework in Malta for addressing these issues is the Prevention of Trafficking in Persons Regulations. In addition, various sections of the Maltese Criminal Code, White Slave Traffic (Suppression) Ordinance (Chapter 63 of the Laws of Malta) 1930 and Employment and Industrial Relations Act 2002 contain relevant guidance.
  • In Cyprus the relevant legal framework is the Prevention and Suppression of Human Trafficking and the Protection of its Victims Law of 2004 (60(I)/2014).
  • In Luxembourg the relevant legal framework includes the Law of 18 April 2004 on the fight against trafficking in human beings and the exploitation of prostitution and the Law of 20 July 2022 on Due Diligence in Supply Chains.

and any other such legislative acts applying at the current time or in the future. We utilise https://antislaverylaw.ac.uk/ as a resource to keep track of such legislation.

This statement constitutes our anti-slavery and human trafficking statement for the financial year ending December 2025. It will be reviewed annually and updated to reflect evolving legislation, regulatory guidance, and operational practices.

“Modern slavery” refers to the offences of human trafficking, slavery, servitude, and forced or compulsory labour;

  • the trafficking of adults into conditions of criminal exploitation
  • the trafficking of adults into conditions of labour exploitation
  • the trafficking of minors into conditions of sexual, criminal or labour exploitation
  • the sexual exploitation of adults
  • other forms of exploitation

Modern slavery includes victims who have been brought from overseas and vulnerable people in the UK and in Ireland who are forced to work illegally against their will across different sectors such as construction, manufacturing, agriculture, hospitality and retail.

“Human trafficking” involves the recruitment, transfer or obtaining of an individual through coercion, abduction, fraud or force to exploit them. Although human trafficking often involves an international cross-border element, it is also possible to be a victim of modern slavery within your own country. There are several broad categories of exploitation linked to human trafficking, including sexual exploitation, forced labour, domestic servitude, organ harvesting, child related crimes, forced marriage and illegal adoption.

“Forced Labour” is all work or service exacted from any person under the menace of penalty and for which that person has not offered themselves voluntarily, as defined in ILO Convention No. 29.

“Child Labour" is any work that deprives children of their childhood, education, or is likely to harm their health or development, as defined in ILO Convention No. 138 and No. 182.

“Supplier" is any third-party entity providing goods, labour, or services to LRC or its affiliates.

Our Business

The LRC Group (“LRC”) and all of the companies within the LRC Group are committed to working to combat slavery and human trafficking. We exercise a zero tolerance approach to slavery and human trafficking.

LRC is a privately held investment and management firm operating from affiliated offices throughout the UK and Europe, but primarily in London, Dublin, Berlin, Warsaw and Larnaca.

The LRC Group consists of the following companies;

  • LRC UK Ltd
  • LRC Management UK Ltd
  • LRC Management Ireland Ltd
  • LRC Management Europe Ltd
  • LRC Real Estate Ltd
  • LRC Group GmbH
  • LRC Poland Sp. Z o.o.
  • Vonder Holding SARL
  • Vonder UK Ltd
  • Vonder X UK Ltd
  • Vonder X Management Ltd
  • Vonder GmbH
  • Vonder Munich GmbH
  • Vonder Poland Sp. Z o.o.
  • Vonder DBI

LRC’s principals have been active in the European real estate markets since 1995 and bring a combined experience of over 125 years in the international property and finance markets to the table.

As an opportunity-driven investment group, LRC is not bound by fixed investment profiles and return requirements and can assess every opportunity based on its individual merits without limitations to asset class, volume or jurisdiction. We have sourced and acquired real estate assets with a total value of over €6bn across Europe. LRC specialises in structuring and executing portfolio transactions from value-add situations and enhances them through strong in-house asset management with a demonstrated track record.

This statement is also made in respect of LRC’s subsidiary undertaking, Vonder, a global co-living lifestyle brand offering beautifully designed urban spaces, emphasizing experiences and a vibrant local community.

Policy on Slavery for the LRC Group

LRC considers the risk of slavery and human trafficking within its business to be low. However, we recognize that modern slavery can occur in any industry, particularly in sectors such as hospitality, where outsourced services and complex supply chains are common. As such, it is the policy of the LRC Group to maintain a zero-tolerance approach to slavery and human trafficking within our business and supply chains, with a particular focus on hospitality services.

To ensure that we are conducting business in an ethical and transparent manner, we operate a number of internal policies and practices, including:

Recruitment. We operate robust recruitment practices, including conducting eligibility to work checks for all employees and contractors to safeguard against human trafficking or individuals being forced to work against their will. LRC staff are protected by relevant laws and regulations, which are fully reflected in the firm’s policies and procedures. Our remuneration packages for all job roles meet, or exceed, the minimum national requirements. Contractors and consultants who are employed or engaged by LRC, carry out highly skilled activities and are therefore deemed low risk. LRC places a high value on each of our employees and ensures all employment practices adhere to national and international labour standards. We offer a work environment where there are equal opportunities, fairness, inclusiveness, mutual respect and diversity. Our policies and procedures are reviewed on a regular basis to enable a supportive, safe and accident-free workplace. Our employees are at the centre of our health and safety programmes.

Whistleblowing. We operate a whistleblowing policy (in accordance with the EU Whistleblower Protection Directive (2019/1937)) so that all employees know they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.

Supply Chain Compliance. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. This anti-slavery and human trafficking statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. A risk based approach has been adopted to review supply chains that fall within industries that carry a higher risk of modern day slavery. We internally review our supply chain to evaluate human trafficking risks and slavery risks and, where appropriate, we review aspects of the supply chain including safety, human trafficking, child labour and other legal requirements.

LRC has owned and operated hotel properties in the past and may do so in the future. These may involve outsourced housekeeping and food & beverages suppliers. With regards to national or international supply chains in food & beverage, we expect these entities to have suitable anti-slavery and human trafficking policies and processes. We expect each entity in the supplier chain to, at least, adopt ‘one-up’ due diligence on the next link in the chain. It is not practical for us (and every other participant in the chain) to have a direct relationship with all links in the food & beverage chain, ultimately to the field or utility generator. Each of LRC and Vonder will annually audit its outsourced housekeeping service providers to ensure that fair practices are in place along with high compliance with employment law.

We recognise and understand the complexities associated with the existence of modern slavery and its potential impact on global supply chain networks and we are committed to working with our Suppliers, Customers, Regulatory Authorities and other parties and organisations, including NGO’s, to support the development of long-term solutions to this issue and its abolition.

Ongoing Monitoring & Collaboration. We acknowledge the complexities of modern slavery and the challenges in global supply chain networks. To enhance our efforts, we engage with suppliers, customers, and regulatory authorities to develop long-term solutions and best practices to combat modern slavery. Our compliance team regularly reviews the effectiveness of our policies and updates them in line with legal and regulatory developments.

Training. Where LRC or Vonder provides an accommodation service, training will be provided to relevant team members to enable them to identify potential signs of slavery, human trafficking or child grooming and sexual exploitation.

We publish this statement on our website and communicate to our suppliers. We provide training to ensure information about our commitment to Anti-Slavery and human trafficking is communicated throughout our business.

The LRC Group’s management team has endorsed this policy and affirms LRC’s commitment to combat Modern Slavery.

Chris Dimitriadis

CEO

Date: 6-Jan-26