Modern Slavery Policy
Mission
Modern slavery is a crime and a serious violation of fundamental human rights. It can take many forms, including slavery, servitude, forced or compulsory labour, and human trafficking. In all cases it involves the exploitation of individuals through the deprivation of their liberty for personal or commercial gain.
Kerv Group is committed to conducting business ethically and with integrity in all our relationships. We take a zero-tolerance approach to modern slavery and human trafficking and are committed to implementing and maintaining effective systems and controls to ensure that it does not occur anywhere within our organisation or our supply chains.
Purpose
The purpose of this policy is to ensure that Kerv maintains appropriate governance, processes, and controls to prevent modern slavery and human trafficking within our business and throughout our supply chain.
Kerv undertakes initiatives within our organisation and across our supplier ecosystem to support responsible business practices and eliminate modern slavery and human trafficking. While all employees share responsibility for ensuring that modern slavery does not occur within our organisation, Kerv allocates appropriate governance oversight and resources to develop and implement our modern slavery strategy and related social responsibility initiatives.
Scope
This policy applies to all individuals working for or on behalf of Kerv Group, including employees, agency workers, seconded workers, interns, contractors, consultants and temporary staff.
It also applies to suppliers, subcontractors, and other third parties who provide goods or services to Kerv.
This policy does not form part of any employee’s contract of employment and may be amended at any time. Where there is any conflict between this policy and contractual arrangements, the higher standard of compliance will apply.
Due to the nature of the services Kerv provides principally technology services, managed services, and professional consulting the risk of modern slavery occurring within our direct workforce is considered low. However, we recognise that risks may exist within broader supply chains and we remain vigilant in identifying and addressing potential concerns.
Compliance with applicable laws and regulations relating to modern slavery is mandatory for all Kerv employees, partners and suppliers.
Definitions
Modern Slavery
Modern slavery refers to situations where individuals are exploited and cannot refuse or leave work due to threats, violence, coercion, deception, or abuse of power. It includes slavery, servitude, forced labour and human trafficking.
Human Trafficking
Human trafficking involves the recruitment, transportation, transfer, harbouring or receipt of individuals through coercion, deception or abuse of power for the purpose of exploitation.
Supply Chain
Supply chain refers to all organisations and individuals involved in providing goods or services to Kerv, including suppliers, subcontractors, and service partners.
Policy
Kerv is committed to maintaining transparency in our operations and supply chains and to addressing the risks of modern slavery and human trafficking in line with applicable legal and regulatory requirements.
To support the prevention, detection and reporting of modern slavery, Kerv will:
- comply with all applicable modern slavery legislation in the jurisdictions in which we operate
- maintain a zero-tolerance approach to slavery, servitude, forced labour and human trafficking
- implement supplier governance and due diligence processes aligned with our Supplier Management Policy
- develop long-standing relationships with reputable suppliers who demonstrate responsible business practices
- require suppliers and contractors to operate in accordance with applicable labour laws and ethical employment standards
- expect suppliers to apply similar standards within their own supply chains
- provide guidance and training to employees so that they understand how to recognise and respond to potential modern slavery risks
- encourage employees and partners to report concerns or suspected breaches of this policy
Roles and Responsibilities
Leadership Team
The Leadership Team is responsible for ensuring that appropriate governance structures, policies, and oversight mechanisms are in place to prevent modern slavery within the organisation and its supply chains.
Group Governance and Compliance Team
The Governance function is responsible for maintaining this policy, supporting supplier due diligence processes, monitoring compliance, and investigating reported concerns relating to modern slavery risks.
People Operations
People Operations is responsible for ensuring recruitment practices comply with employment legislation and for identifying potential indicators of labour exploitation during hiring processes.
Employees and Contractors
All employees and contractors are responsible for complying with this policy and reporting any concerns relating to modern slavery or unethical labour practices.
Suppliers and Partners
Suppliers and partners working with Kerv are expected to operate in accordance with applicable labour laws and ethical employment standards and to apply similar expectations within their own supply chains.
Evaluating Suppliers
Kerv applies due diligence procedures when engaging new suppliers and periodically reviewing existing supplier relationships.
As part of our supplier onboarding process, suppliers may be required to complete due diligence questionnaires covering compliance with modern slavery legislation and ethical labour practices. This helps Kerv assess potential risks associated with a supplier’s operations and supply chain.
Where issues or concerns are identified during supplier evaluation, further investigation will be conducted by the Group Governance Team and Compliance Manager. Where necessary, mitigation measures may be implemented or the supplier relationship reconsidered.
Staff Recruitment and Training
Kerv operates responsible recruitment practices to ensure all employees are legally entitled to work and are employed in accordance with applicable employment laws.
As part of our recruitment process, identity verification, right-to-work checks, reference checks and, where appropriate, criminal record and qualification checks are carried out through an independent screening provider.
People Operations teams are trained to identify potential indicators of labour exploitation or irregularities during recruitment processes and will investigate any concerns that may arise.
Employees are expected to comply with all applicable laws and act with integrity and honesty in their work. Where relevant, training and awareness programmes may be provided to help employees understand modern slavery risks and their responsibilities under this policy.
Acquisition Due Diligence
As part of Kerv’s growth strategy, the organisation periodically acquires and integrates new businesses.
Where acquisitions are considered, appropriate due diligence is conducted to assess legal, operational, financial and governance risks associated with the target organisation. This includes consideration of potential modern slavery risks within the target entity, its operations, and its supplier relationships.
Where necessary, mitigation actions may be implemented during the integration process to ensure alignment with Kerv’s governance standards.
Indicators of Modern Slavery
Employees should remain aware of potential warning signs that may indicate modern slavery or labour exploitation. These indicators may include:
- individuals appearing to be under the control of others or unable to speak for themselves
- workers lacking personal identification documents or access to their own documentation
- unusual working or living arrangements that may suggest coercion or exploitation
- signs of intimidation, fear, or reluctance to engage with authorities or management
- workers receiving little or no pay or working excessive hours without appropriate conditions
These indicators do not necessarily mean modern slavery is occurring but should prompt further review or reporting where concerns arise.
Reporting Concern
Kerv encourages employees, suppliers and partners to report any concerns relating to suspected modern slavery or breaches of this policy.
If you believe or suspect that a breach of this policy has occurred, or may occur in the future, you should contact the Group Governance Team at: group.governance@kerv.com
All reports will be treated seriously and investigated in accordance with Kerv’s governance and compliance procedures.
Breaches of this Policy
Any employee found to be in breach of this policy may be subject to disciplinary action, which may include dismissal for misconduct or gross misconduct.
Kerv may terminate relationships with suppliers, contractors or other third parties working on our behalf if they are found to be in breach of this policy.
Related Policies
This policy should be read in conjunction with the following policies:
- Recruitment and Selection Policy
- Supplier Management Policy
- Equal Opportunities Policy
- Code of Conduct
- Whistleblowing Policy
Policy Review and Governance
This policy is owned by the Group Governance function and will be reviewed periodically to ensure it remains aligned with legal requirements, regulatory expectations, and Kerv’s operational practices.
The policy may be updated where required to reflect:
- changes in legislation or regulatory guidance
- changes in Kerv’s business operations or supply chain structure
- emerging risks associated with modern slavery and human trafficking
Material updates to this policy will be approved by senior management.
Authorisation
This policy forms part of Kerv’s broader governance and compliance framework and supports the organisation’s commitment to preventing modern slavery within its operations and supply chains.
Approved and authorised by:
