Effective Date: 1 January 2024
Kinhub is committed to preventing modern slavery and human trafficking in all aspects of its operations and supply chains. This policy outlines our approach to identifying, preventing, and addressing risks related to modern slavery and human trafficking.
Modern Slavery: Practices including slavery, servitude, forced and compulsory labour, and human trafficking, as defined by the Modern Slavery Act 2015.
Human Trafficking: The recruitment, transportation, transfer, harbouring, or receipt of persons by means of threat, force, coercion, abduction, fraud, or deception for the purpose of exploitation.
Kinhub is dedicated to maintaining the highest ethical standards and ensuring that all our business activities are free from modern slavery and human trafficking. We are committed to:
Complying with all applicable laws and regulations related to modern slavery and human trafficking.
Conducting business in an ethical, transparent, and responsible manner.
Board of Directors:
Oversee the implementation and enforcement of this policy.
Ensure adequate resources are available to address modern slavery risks.
Managers:
Promote awareness of modern slavery and human trafficking within their teams.
Ensure compliance with this policy in their respective areas of responsibility.
Employees:
Report any concerns regarding modern slavery or human trafficking.
Adhere to the principles and guidelines outlined in this policy.
Kinhub will conduct thorough due diligence to identify and mitigate modern slavery risks within our operations and supply chains.
This includes:
Risk Assessment: Regularly assessing the risk of modern slavery in our operations and supply chains.
Supplier Vetting: Ensuring all suppliers and contractors comply with our ethical standards and legal obligations concerning modern slavery.
Contracts: Including modern slavery clauses in contracts with suppliers and contractors to ensure compliance.
Kinhub will provide training and resources to ensure employees are aware of modern slavery issues and understand their roles in preventing it. This includes regular training sessions on modern slavery and human trafficking for all employees.
Kinhub will provide the following specific training and resources to ensure employees are aware of modern slavery issues and understand their roles in preventing it:
Mandatory Training Programmes:
Develop and implement mandatory training sessions on modern slavery and human trafficking for all employees, including new hires, during onboarding.
Tailor training approach and content to different organisational roles and responsibilities, ensuring relevance and practicality (for example providing enhanced training to senior managers and individuals directly involved in matters impacting staff and supplier/partner recruitment).
Training may include interactive e-learning modules that cover key topics (such as the definitions and indicators of modern slavery, legal obligations, and reporting procedures) and quizzes and assessments to reinforce learning and measure understanding.
Workshops and Seminars:
Conduct workshops and seminars to discuss modern slavery issues, share best practices, and provide real-life case studies.
Encourage active participation and discussion to deepen understanding and engagement.
Resource Materials:
Distribute comprehensive resource materials, including guides, checklists, and reference documents, that employees can easily access and refer to as needed.
Ensure materials are updated regularly to reflect changes in legislation and emerging best practices.
Kinhub encourages employees and stakeholders to report any concerns related to modern slavery and human trafficking. We will ensure:
Confidential Reporting: A confidential whistleblowing mechanism is in place for reporting concerns.
To ensure the effectiveness of the confidential whistleblowing mechanism for reporting concerns related to modern slavery and human trafficking, Kinhub will implement the following measures:
Clear Communication Channels:
Provide multiple, easily accessible channels for whistleblowing, including a secure online reporting system, and an anonymous email address.
Clearly communicate these channels to all employees, suppliers, and stakeholders through various platforms, including the company intranet, training sessions, and supplier meetings.
Anonymity and Confidentiality:
Ensure that all reports can be made anonymously and that the whistleblower's confidentiality is maintained at all times.
Use secure technology and data protection measures to safeguard the identity and information of the whistleblower.
Non-Retaliation Policy:
Implement a strict non-retaliation policy to protect whistleblowers from retaliation, discrimination, or negative consequences of their report(s).
Communicate this policy clearly to all employees and stakeholders to encourage reporting without fear of repercussion.
Independent Oversight:
Assign an independent and dedicated individual or team to manage and oversee the whistleblowing mechanism, ensuring impartiality and thorough investigation of all reports.
Regularly audit the whistleblowing process to ensure compliance with best practices and regulatory standards.
Feedback and Improvement:
Establish a feedback mechanism where whistleblowers can receive updates on the status of their reports, where possible and appropriate.
Use feedback and data from whistleblowing cases to continuously improve the reporting mechanism and address any identified gaps or issues.
Kinhub will regularly monitor and review the effectiveness of this policy to ensure it remains relevant and effective. This includes:
Annual Review: Conducting an annual review of the policy and its implementation.
Performance Indicators: Developing key performance indicators to measure the effectiveness of our efforts to combat modern slavery.
Kinhub is committed to continuous improvement in our approach to tackling modern slavery. We will take the following steps to engage with stakeholders, including suppliers, employees, and external experts, to enhance their understanding and response to modern slavery risks:
Supplier Engagement:
Develop and distribute a Supplier Code of Conduct that outlines Kinhub’s expectations regarding modern slavery and human trafficking.
Conduct regular supplier audits and assessments to ensure compliance with the Code of Conduct and identify any potential risks.
Where necessary, provide suppliers with training and resources to help them understand modern slavery issues and implement effective prevention measures within their own operations.
Employee Involvement:
Encourage employees to participate in external events and networks related to modern slavery to gain broader perspectives and share knowledge within the organisation.
Collaboration with External Experts:
Invite external experts to conduct training sessions, audits, and reviews of Kinhub’s policies and practices, providing valuable insights and recommendations.
Stakeholder Forums:
Organise forums and roundtable discussions with key stakeholders, including suppliers, customers, and community representatives, to discuss modern slavery risks and collaboratively develop solutions.
Use these forums to share Kinhub’s progress, challenges, and plans for continuous improvement, fostering transparency and accountability.
Public Reporting:
Publish an annual Modern Slavery Statement outlining Kinhub's steps to prevent modern slavery.
Ensure the statement is publicly available on Kinhub’s website and communicated to all stakeholders to demonstrate commitment and build trust.
Innovation:
Explore new technologies and methodologies to improve our detection and prevention efforts with regards to modern slavery.
Kinhub is committed to continuous improvement in our approach to tackling modern slavery. We will take the following steps to engage with stakeholders, including suppliers, employees, and external experts, to enhance their understanding and response to modern slavery risks:
Supplier Engagement:
Develop and distribute a Supplier Code of Conduct that outlines Kinhub’s expectations regarding modern slavery and human trafficking.
Conduct regular supplier audits and assessments to ensure compliance with the Code of Conduct and identify any potential risks.
Provide suppliers with training and resources to help them understand modern slavery issues and implement effective prevention measures within their own operations.
Employee Involvement:
Encourage employees to participate in external events and networks related to modern slavery to gain broader perspectives and share knowledge within the organisation.
Collaboration with External Experts:
Invite external experts to conduct training sessions, audits, and reviews of Kinhub’s policies and practices, providing valuable insights and recommendations.
Stakeholder Forums:
Organise regular forums and roundtable discussions with key stakeholders, including suppliers, customers, and community representatives, to discuss modern slavery risks and collaboratively develop solutions.
Use these forums to share Kinhub’s progress, challenges, and plans for continuous improvement, fostering transparency and accountability.
Public Reporting:
Publish an annual Modern Slavery Statement outlining Kinhub's steps to prevent modern slavery.
Ensure the statement is publicly available on Kinhub’s website and communicated to all stakeholders to demonstrate commitment and build trust.
Innovation:
Explore new technologies and methodologies to improve our detection and prevention efforts.
This policy has been approved by the Board of Directors and will be reviewed annually. It is published on our website and available to all employees and stakeholders.