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01480 407304
sales@kiteus.co.uk

PURPOSE

The purpose of this policy is to establish KITE Utility Services Ltd’s commitment to preventing modern slavery, human trafficking, forced labour, servitude and all forms of exploitation within its business operations and supply chains. KITE is committed to respecting human rights, protecting workers from exploitation and conducting business ethically, responsibly and in accordance with applicable UK legislation.

This policy sets out the responsibilities of management, employees, subcontractors and suppliers for identifying, preventing, reporting and addressing actual or suspected cases of modern slavery and human trafficking.

SCOPE

This policy applies to all KITE employees, directors, subcontractors, suppliers and other parties undertaking work or providing goods or services on behalf of the Company.

KITE expects all business partners and supply-chain organisations to uphold the principles of this policy and comply with applicable legislation.

STATUS AND REVIEW

This is a Company Policy and does not form part of a collective agreement. KITE reserves the right to amend this policy from time to time, subject to applicable legal requirements.

The policy will be reviewed at least annually and sooner where required by changes in legislation, business activities, supply-chain risks or identified incidents.

POLICY STATEMENT

KITE has a zero-tolerance approach to modern slavery and human trafficking.

The Company will not knowingly engage in, facilitate or tolerate slavery, servitude, forced or compulsory labour, human trafficking, child exploitation or any other form of unlawful labour exploitation within its operations or supply chains.

KITE is committed to:

• Treating all workers fairly, with dignity and respect.

• Ensuring employment practices comply with applicable employment and human rights legislation.

• Taking reasonable steps to identify, assess and address modern slavery risks within its operations and supply chains.

• Conducting appropriate checks on employees, subcontractors, labour providers and suppliers.

• Communicating its expectations clearly to employees, subcontractors, labour providers and suppliers .

• Providing appropriate training and guidance to help employees recognise potential indicators of exploitation.

• Providing a safe and confidential means of reporting concerns.

• Investigating allegations promptly, sensitively and impartially.

• Taking appropriate corrective action where modern slavery risks or breaches are identified.

KITE recognises that modern slavery can occur in any country, industry or supply chain and that exploitation may not always be immediately apparent.

LEGAL AND REGULATORY COMPLIANCE

KITE will comply with applicable legislation relating to modern slavery, human trafficking, employment and worker protection, including, where applicable:

• Modern Slavery Act 2015.

• Human Rights Act 1998.

• Employment Rights Act 1996.

• National Minimum Wage Act 1998 and applicable minimum wage regulations.

• Applicable immigration, recruitment and employment legislation.

KITE will monitor relevant legal developments and update its procedures where necessary.

Where the Company meets the statutory criteria under section 54 of the Modern Slavery Act 2015, it will comply with the applicable requirements for preparing, approving and publishing an annual modern slavery statement.

RESPONSIBILITIES

Company Management

Company Management has overall responsibility for implementing and monitoring this policy.

Management will:

• Ensure appropriate procedures are in place to identify and manage modern slavery risks.

• Allocate suitable resources for training, supplier checks and investigations.

• Ensure recruitment and onboarding arrangements include appropriate checks.

• Assess risks associated with suppliers, subcontractors and labour providers.

• Ensure concerns are investigated promptly and handled confidentially.

• Protect individuals who raise concerns in good faith from retaliation.

• Take appropriate corrective action where non-compliance is identified.

• Review the effectiveness of the Company's arrangements at least annually.

• Ensure any statutory reporting or publication requirements are met where applicable.

6.2 Employees

All employees must:

• Comply with this policy and complete any required training.

• Treat colleagues, subcontractors and other workers fairly and respectfully.

• Remain alert to possible indicators of exploitation.

• Report suspected modern slavery or human trafficking promptly.

• Cooperate with authorised investigations where appropriate.

• Avoid taking action that could place a potential victim or reporting individual at further risk.

Employees must not engage in, facilitate or knowingly benefit from modern slavery or human trafficking.

6.3 Subcontractors and Suppliers

All subcontractors and suppliers must:

• Comply with applicable modern slavery, employment and human rights legislation.

• Prohibit forced labour, human trafficking, slavery, servitude and unlawful child labour within their operations.

• Ensure workers are employed voluntarily and are treated fairly.

• Ensure workers are paid in accordance with applicable legal and contractual requirements.

• Not retain workers' identity documents unlawfully or use threats, coercion, debt bondage or other practices to restrict freedom of movement.

• Ensure recruitment fees and employment arrangements do not create unlawful debt or coercion.

• Communicate these requirements to relevant subcontractors, labour providers and other supply-chain partners.

• Cooperate with reasonable KITE requests for information, checks or corrective action relating to modern slavery risks.

• Report suspected or confirmed cases affecting work undertaken for KITE.

Suppliers are expected to take reasonable steps to assess and address risks beyond their immediate operations, including risks involving their own suppliers and subcontractors.

7. IMPLEMENTATION AND DUE DILIGENCE

KITE will take a proportionate, risk-based approach to identifying and managing modern slavery risks.

7.1 Recruitment and employment

KITE will maintain appropriate recruitment and onboarding procedures, including relevant identity, right-to-work and employment checks where legally required.

Recruitment practices must be fair and transparent. Workers must understand the terms and conditions of their employment and must not be subjected to coercion, threats, unlawful deductions or restrictions intended to prevent them from leaving employment.

KITE will not knowingly use recruitment practices that facilitate exploitation.

7.2 Supplier and subcontractor checks

Before engaging suppliers, subcontractors or labour providers, KITE will undertake checks appropriate to the level of risk.

These may include:

• Verifying the legitimacy and identity of the organisation.

• Reviewing relevant employment and labour-supply arrangements.

• Checking applicable licences, registrations and compliance records.

• Requesting confirmation of compliance with this policy.

• Reviewing modern slavery policies or statements where available and relevant.

• Assessing the use of further subcontractors.

• Conducting further checks where the nature, location or circumstances of the supply chain indicate increased risk.

Higher-risk arrangements may require enhanced due diligence, periodic reviews or additional contractual controls.

7.3 Ongoing monitoring

KITE will review supplier relationships and investigate credible concerns about possible exploitation.

Where appropriate, the Company may request supporting evidence, conduct audits or inspections, require corrective action and review whether the supplier remains suitable for continued engagement.

The level of monitoring will reflect the nature and severity of the identified risks.

8. IDENTIFYING MODERN SLAVERY

Modern slavery may involve forced labour, human trafficking, servitude, debt bondage or other forms of exploitation.

Potential indicators may include:

• A worker appearing frightened, threatened, controlled or unable to speak freely.

• Another person controlling a worker's identity documents, money or communications.

• Workers being prevented from leaving accommodation or the workplace freely.

• Evidence of threats, intimidation, violence or coercion.

• Workers being required to repay unreasonable recruitment fees or debts.

• Wages being withheld or unlawful deductions being made.

• Working or living conditions that indicate serious exploitation.

• Workers being transported, accommodated or supervised in suspicious or coercive circumstances.

These indicators do not automatically establish that modern slavery has occurred. Concerns must nevertheless be taken seriously and assessed appropriately.

Employees and business partners should not attempt to conduct their own intrusive investigations or confront suspected perpetrators where doing so could endanger a potential victim or compromise a formal investigation.

9. REPORTING CONCERNS

Any employee, subcontractor, supplier or other person who suspects modern slavery or human trafficking within KITE's operations or supply chains must report the concern as soon as reasonably practicable.

Concerns should be reported to:

• The employee's line manager or supervisor.

• A member of KITE Management.

• The Managing Director, where appropriate.

If the concern involves the usual reporting contact, or the individual does not feel comfortable reporting through that route, it should be raised with another appropriate member of management.

Reports should include relevant information about the concern, such as the location, activity, people involved and any observed indicators, where it is safe and appropriate to provide these details. Reports will be handled sensitively, with information shared only where necessary and lawful.

No employee or other person will be subjected to retaliation, victimisation or disadvantage for raising a genuine concern in good faith or cooperating with an investigation. Where there is an immediate threat to life or safety, the police should be contacted on 999.

Suspected modern slavery may also be reported to the UK Modern Slavery & Exploitation Helpline on 0800 0121 700 or through its online reporting service.

10. INVESTIGATION AND RESPONSE

KITE Management will ensure that all reported concerns are assessed promptly and investigated appropriately.

The response will be proportionate to the circumstances and will prioritise the safety, dignity and welfare of any person who may be at risk.

Where appropriate, the Company will:

• Assess immediate risks to the individual and others.

• Take reasonable steps to protect potential victims from further harm.

• Preserve relevant information and records.

• Seek specialist advice or involve the appropriate authorities where necessary.

• Investigate the concern impartially and maintain appropriate records.

• Review the involvement of any supplier, subcontractor or labour provider.

• Implement corrective measures and monitor their effectiveness.

• Consider whether further reporting or referral is required.

KITE will not tolerate attempts to conceal exploitation, intimidate individuals who report concerns or obstruct an investigation. Where a breach is substantiated, the Company may require remedial action, suspend work, restrict further engagement or terminate a contractual relationship, depending on the seriousness of the breach and the circumstances.

Any response will take account of the need to protect affected workers and avoid exposing them to further harm. Contract termination will not be treated as an automatic substitute for assessing the risks to affected individuals and considering appropriate action.

11. TRAINING AND COMMUNICATION

KITE will communicate this policy to employees, relevant subcontractors and suppliers.

Appropriate training, induction information or briefings will be provided according to the person's role and exposure to modern slavery risks.

Training and communication will cover:

• The meaning and forms of modern slavery.

• Potential indicators of exploitation.

• Responsibilities under this policy.

• How to report concerns.

• The importance of confidentiality and victim protection.

• The Company's expectations of suppliers and subcontractors.

KITE will retain appropriate records of training and communication.

12. RECORD KEEPING AND CONFIDENTIALITY

KITE will maintain appropriate records of supplier checks, reported concerns, investigations, corrective actions and relevant training.

Records will be stored securely and retained in accordance with applicable legal requirements and Company procedures.

Personal information relating to potential victims, reporting individuals or investigations will be handled confidentially and in accordance with applicable data protection legislation.

Information will be shared with external organisations or authorities where necessary, appropriate and lawful.

13. NON-COMPLIANCE

Any employee who breaches this policy may be subject to investigation and disciplinary action in accordance with KITE's Disciplinary Policy and Procedure.

Subcontractors and suppliers who breach this policy may be required to implement corrective action or may have their work suspended or their contracts terminated, subject to the circumstances and applicable contractual arrangements.

KITE will take appropriate action against any person who knowingly facilitates, conceals or retaliates against the reporting of modern slavery or human trafficking.

14. MONITORING AND REVIEW

KITE will monitor the effectiveness of this policy through appropriate management reviews, supplier due diligence, training records, investigations and corrective action monitoring.

The policy will be reviewed at least annually and following any significant incident, material change in business operations or relevant legislative development.

Improvements will be implemented where necessary to strengthen the Company's prevention, detection and response arrangements.

 

 

 

Dayle Humphrey

Date 10 October 2026

Review Date 31 October 2027