UK Modern Slavery Act

ANTI-SLAVERY POLICY STATEMENT

Modern slavery is a crime and a violation of fundamental human rights. It takes various
forms, such as slavery, servitude, forced and compulsory labor, and human trafficking, all of
which have in common the deprivation of a person’s liberty by another to exploit them for
personal or commercial gain. The Company has a zero-tolerance approach to modern slavery,
and we are committed to acting ethically and with integrity in all our business dealings and
relationships and to implement and enforce effective systems and controls to ensure
modern slavery is not taking place anywhere in our own business or in any of our supply
chains. We are also committed to ensuring there is transparency in our own business and in
our approach to tackling modern slavery throughout our supply chains, consistent with our
disclosure obligations under the Modern Slavery Act 2015. We expect the same high
standards from all our contractors, suppliers, and other business partners, and as part of our
contracting processes, in the coming year we will include specific prohibitions against the use
of forced, compulsory, or trafficked labor, or anyone held in slavery or servitude, whether
adults or children and we expect that our suppliers will hold their own suppliers to the same
high standards. This policy applies to all persons working for us or on our behalf in any
capacity, including employees at all levels, directors, officers, agency workers, seconded
workers, volunteers, interns, agents, contractors, external consultants, third-party
representatives, and business partners. This policy does not form part of any employee’s
contract of employment, and we may amend it at any time.

1. Responsibility for the policy
The Company has overall responsibility for ensuring this policy complies with our legal and
ethical obligations, and that all those under our control comply with it. The Company has
primary and day-to-day responsibility for implementing this policy, monitoring its use and
effectiveness, dealing with any queries about it, and auditing internal control systems and
procedures to ensure they are effective in countering modern slavery. Management at all
levels is responsible for ensuring those reporting to them understand and comply with this
policy and are given adequate and regular training on it and the issue of modern slavery in
supply chains. You are invited to comment on this policy and suggest ways in which it might
be improved. Comments, suggestions, and queries are encouraged and should be addressed
to the Managing Director. [admin@kiprom.co.uk]

2. Compliance with the policy
You must ensure that you read, understand, and comply with this policy. The prevention,
detection, and reporting of modern slavery in any part of our business is the responsibility of
all those working for us or under our control. You are required to avoid any activity that
might lead to, or suggest, a breach of this policy. You must notify your line manager OR a
company Director as soon as possible if you believe or suspect that a conflict with this policy
has occurred or may occur in the future.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any
part of our business. If you believe or suspect a breach of this policy has occurred or that it
may occur, you must notify your line manager or company Director OR report it in
accordance with our Whistleblowing Policy as soon as possible. You should note that where
appropriate, and with the welfare and safety of local workers as a priority, we will give
support and guidance to our suppliers to help them address coercive, abusive, and
exploitative work practices in their own businesses and supply chains. If you are unsure about
whether a particular act, the treatment of workers more generally, or their working
conditions within any tier of our supply chains constitutes any of the various forms of modern
slavery, raise it with your line manager or company Director. We aim to encourage openness
and will support anyone who raises genuine concerns in good faith under this policy, even if
they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental
treatment because of reporting in good faith their suspicion that modern slavery of whatever
form is or may be taking place in any part of our own business. Detrimental treatment
includes dismissal, disciplinary action, threats, or other unfavorable treatment connected
with raising a concern. If you believe that you have suffered any such treatment, you should
inform your line manager immediately. If the matter is not remedied, and you are an
employee, you should raise it formally using our Grievance Procedure, which can be found in
the current employee handbook. This Modern (Anti) Slavery Policy and Statement is intended
for businesses in all countries, especially the United Kingdom.

3. Communication & awareness of this policy
Training on this policy, and on the risk, our business faces from modern slavery in its supply
chains, forms part of the induction process for all individuals who work for us, and updates
will be provided using established methods of communication between the business and you.
Our zero-tolerance approach to modern slavery must be communicated to all suppliers,
contractors, and business partners at the outset of our business relationship with them and
reinforced as appropriate thereafter.

4. Breaches of this policy
Any employee who breaches this policy will face disciplinary action, which could result in
dismissal for misconduct or gross misconduct. We may terminate our relationship with other
individuals and organizations working on our behalf if they breach this policy.
 

Warrington, 9th January 2023

Khariche Oussama
Managing Director
Kiprom UK Ltd.