Modern Slavery Policy

Mission

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour 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. 

Purpose

The purpose of this policy is to ensure that we implement and enforce effective controls to ensure that modern slavery is not taking place anywhere in our own business or in any of our supply chains.  

Kerv will undertake a variety of initiatives within our business and supply chains, making sure that we our working together with our staff and suppliers to eliminate modern slavery and human trafficking.  While all our people have a part to play in ensuring that modern slavery does not take place, we will allocate resources to specifically devise and implement our modern slavery strategy and other social initiatives.

Scope

This policy applies to all stakeholders including all suppliers, employees, agency workers, seconded workers, interns, contractors and external consultants.  

This policy does not form part of any employee’s contract of employment, and we may amend it at any time.  In an instance where there is a conflict between this policy and any contract then the higher standard should apply.

We believe the risk of slavery within our own business is low due to the nature of services we offer, and our supply chain is principally the supply of IT resource and consulting, we nevertheless continue to be mindful of the possible risks and implement appropriate measures to combat these.

Adherence to local laws and regulations regarding modern slavery is a non-negotiable item for us.

Policy

We are committed to ensuring that there is transparency in our own business and in our approach to tackling modern slavery and human trafficking throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. To ensure the prevention, detection and reporting of modern slavery and human trafficking in any part of our business or supply chains it is our policy to:

• ensure full compliance with local and national modern slavery laws in the regions in which we operate;
• build long standing relationships with our suppliers all of whom are assessed in line with our Supplier Management Policy
• have zero tolerance to slavery and human trafficking;
• require all those in our supply chain and our contractors to comply with our values and we expect that our suppliers will hold their own suppliers to the same high standards. Our point of contact for national or international supply chains is preferably with a UK, and we expect these entities to have in place suitable anti-slavery and human trafficking policies and processes; assess via our Supplier Due Diligence process
• train our staff to avoid any activity that might lead to, or suggest, a breach of this policy and notify the Governance Team immediately if they believe or suspect that a conflict with this policy has occurred or may occur in the future.  

Evaluating suppliers

We pay great attention to the appointment of new suppliers. We require potential suppliers to complete a core set of questions to ensure they comply with modern slavery legislation and manage the risks/issues present within their business and their supply chain, as well as about the safeguards they have in place. 

Should issues or concerns be raised during any evaluation process with a potential supplier then further investigation will take place under the guidance of Group Governance Team and Compliance Manager.  

Staff Recruitment and Training

As part of our recruitment process for employees, we carry out checks prior to any person joining. Our People Operations looks for potential red flags for modern slavery and will follow up on any irregularities which may indicate that there is an issue.  The pre-screening is carried-out by a specialist independent screening provider, who performs identity checks, reference checks, right to work checks, criminal record checks, and where applicable education and professional qualification checks.  

All staff within Kerv are expected to comply with all laws and act in accordance with local guidelines and regulations and act with integrity and honesty. All staff are required to attend any mandatory training program on modern slavery and human trafficking. Should any of our colleagues need any additional information or support regarding human trafficking, forced labour, servitude, and slavery this will be provided.

Relevant Policies:

• Recruitment and Selection Policy
• Supplier Management Policy
• Equal Opportunities Policy

1. Acquisition due diligence

In line with our purposeful growth strategy, we are particularly active in the acquisitions market, purchasing and integrating businesses with varying structures and operations.  Our Leadership team in evaluating any acquisition will conduct appropriate due diligence over any target entity Kerv is considering acquiring. This includes assessing modern slavery risks in the target, its suppliers, and its business relationships.

2. Reporting

If you believe or suspect a breach of this policy has occurred or that it may occur, you must contact us on group.governance@kerv.com as soon as possible.  

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 please contact us group.governasnce@kerv.com  

3. 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 organisations working on our behalf if they breach this policy. 

4. Authorisaion  

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group’s modern slavery and human trafficking statement for the current financial year.    This Policy Statement has been approved & authorised by:  

Name: Mike Ing

Position: Managing Director, Kerv

Date:  01 July 2024

Responsibility

The Chief People Officer along with Kerv’s Senior Management team are responsible for this policy and its implementation. We commit to providing the relevant resource and to reviewing this policy annually and communicating it within the organisation and to external interested parties.

Legal Responsibilities

This policy complies with and supports the Modern Slavery Act 2015.

External Assurance

This policy has been written to comply with the requirements of ISO 9001