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Modern Slavery Statement

This statement was last reviewed on: 21 April 2023.

Kocho’s Commitment

Kocho is committed to operating ethically and honestly in all its business dealings and takes a zero tolerance approach to any form of modern slavery or human trafficking. We are fully committed to preventing slavery and human trafficking in our operation and supply chain, focusing on the following objectives:

  • Ensuring that consideration of modern slavery risks and prevention are added to key policy review processes as an employer and procurer of goods and services.
  • Ensuring that staff involved in buying/procurement and the recruitment and deployment of workers receive training on modern slavery and ethical employment practices.
  • Providing awareness training to staff on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect a case of slavery or human trafficking.

Due Diligence

Our Supplier Onboarding Process makes specific reference to slavery and human trafficking in the due diligence questionnaire submitted to all potential new suppliers. Due diligence in this area is also part of the ongoing reviews of our existing suppliers.

In particular, we ask all our suppliers to attest that:

  • They don’t use any form of forced, compulsory or slave labour;
  • Their employees work voluntarily and are entitled to leave work;
  • Each employee is provided with an employment contract that contains a reasonable notice period for terminating their employment;
  • Employees are not required to post a deposit/bond and their salary is not withheld for any reason;
  • Employees are not required to surrender their passports or work permits as a condition of employment with that supplier.

To date, we have not been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but, if we were, would take robust action against that supplier.

Risk Assessment and Management

Risks associated with modern slavery are managed via the Kocho risk management framework, which helps determine our response and the controls that we implement. In addition:

  • Our Modern Slavery Policy is made available to all employees. The requirement to familiarise themselves with the Policy is one of the compliance obligations required of all employees;
  • Where an employee suspects an instance of slavery or human trafficking, they must immediately report it to their Line Manager, the Head of Compliance or a member of the Senior Leadership Team.

Associated policies support our efforts in identifying and preventing slavery and human trafficking in our operation, namely:

  • Employee Code of Conduct: This encapsulates the three values of ‘Do what’s right’, ‘Think greater’ and ‘Better together’ and encourages our employees to exhibit the highest standards of conduct and ethical behaviour when representing our company or managing our supply chain.
  • Whistleblowing Policy: Kocho is committed to ensuring that no employee will suffer any repercussions from reporting any suspicion of slavery or human trafficking. To this end, the Whistleblowing Policy is available to all employees and details how they can report any suspicions without fear of retaliation.
  • Supplier Code of Conduct: The Supplier Onboarding Process makes specific reference to slavery and human trafficking, and requires our suppliers to commit to the same high standards of conduct and behaviour that we expect of our employees. Kocho does not do business with suppliers who cannot commit to such an undertaking.

Compliance and KPIs

To demonstrate compliance with the legal requirements of the Modern Slavery Act:

  • We update our Modern Slavery Policy at the start of each financial year, and publish this Modern Slavery Statement on our website;
  • The Modern Slavery Policy and Statement are approved by the Board of Directors and signed off by a Board member;
  • All employees receive a Modern Slavery awareness course as part of their annual training programme.

We have also put in place key performance indicators and controls in relation to the prevention of modern slavery and trafficking in our business and supply chain:

  • Number/percentage of employees who have completed training;
  • Number/percentage of suppliers who have completed our due diligence questionnaire;
  • Number of reported incidences of non-conformance made by our employees.
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