​Scope and Application

This policy applies to all individuals working for or on behalf of Kinisis Solutions in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, and suppliers.

 

Our Commitment

Kinisis Solutions is unequivocally committed to combating modern slavery and human trafficking in all its forms. We maintain a zero-tolerance stance toward these practices within our operations and throughout our supply chains. Our commitment extends to implementing robust systems and controls to ensure modern slavery has no place in our business ecosystem.

We hold our suppliers to the same exacting standards and expect them to cascade these requirements throughout their own supply networks.

POLICY FRAMEWORK

Definition and Recognition

Modern slavery encompasses slavery, servitude, forced and compulsory labour, bonded labour, child labour, and human trafficking. Human trafficking involves arranging or facilitating another person's travel with the intent of exploitation. These practices constitute serious crimes and fundamental violations of human rights.

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1.Core Commitments

Kinisis Solutions expects all stakeholders working with us or on our behalf to uphold the following principles:

(a) Zero Tolerance
We maintain an absolute zero-tolerance approach to modern slavery within our organization and supply chains.

(b) Shared Responsibility
Prevention, detection, and reporting of modern slavery is the collective responsibility of everyone associated with our organization. All workers must refrain from engaging in, facilitating, or failing to report activities that may constitute or suggest policy violations.

(c) Risk-Based Assessment
We employ a comprehensive risk-based approach to our contracting processes, continuously reviewing and updating our procedures. We evaluate circumstances that warrant specific anti-modern slavery clauses in third-party contracts and assess the necessity of requiring supplier compliance with our Code of Conduct.

(d) Enhanced Due Diligence
Consistent with our risk-based methodology, we may require:

• Employment and recruitment agencies and third-party worker suppliers to confirm Code of Conduct compliance

• Suppliers utilizing third-party workers to secure adherence agreements from those parties

(e) Ongoing Monitoring
As part of our continuous risk assessment and due diligence processes, we evaluate circumstances requiring supplier audits for Code of Conduct compliance.

(f) Remedial Action
When individuals or organizations working on our behalf breach this policy, we take appropriate action. This ranges from remediation support (prioritizing affected individuals' welfare) to relationship termination when necessary.

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2. COMPLIANCE REQUIREMENTS

(a) Understanding and Adherence
All stakeholders must read, understand, and comply with this policy in its entirety.

(b) Raising Concerns
We actively encourage the reporting of any issues or concerns related to this policy.

(c) Immediate Reporting
Any belief or suspicion of policy conflicts, whether current or potential, must be reported to your manager immediately.

(d) Whistleblowing Procedures
Suspected policy breaches must be reported to your manager or through our Whistleblowing Policy without delay. Where appropriate, and prioritizing local worker welfare and safety, we may provide guidance and support to suppliers addressing exploitative practices in their operations and supply chains.

(e) Seeking Clarification
If uncertain whether specific acts, worker treatment, or working conditions within our supply chains constitute modern slavery, consult your manager immediately.

(f) Protection and Support
We foster an environment of openness and support all individuals raising genuine concerns in good faith, even if ultimately unfounded. We guarantee protection from detrimental treatment (including dismissal, disciplinary action, threats, or unfavorable treatment) for good-faith reporting of suspected modern slavery. Any experience of such treatment should be reported to your manager immediately. Unresolved matters should be escalated through our formal Grievance Procedure.

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3. COMMUNICATION AND AWARENESS

(a) Training and Development
Comprehensive training on this policy and modern slavery risks forms an integral part of our induction process for all personnel. Regular refresher training is provided as required.

(b) Stakeholder Communication
Our zero-tolerance approach is communicated to all suppliers, contractors, and business partners at the commencement of our relationship and reinforced regularly thereafter.

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4. POLICY VIOLATIONS

(a) Employee Consequences
Employees breaching this policy face disciplinary action, potentially including dismissal for misconduct or gross misconduct.

(b) Third-Party Relationships
We reserve the right to terminate relationships with individuals and organizations that violate this policy.

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5. POLICY OBJECTIVES

This policy aims to:

(a) Encourage Reporting
Foster an environment where staff feel confident reporting suspected wrongdoing, knowing their concerns will be thoroughly investigated with appropriate confidentiality measures.

(b) Provide Clear Guidance
Offer comprehensive guidance on raising concerns and accessing support channels.

(c) Ensure Protection
Guarantee that staff can raise genuine concerns in good faith without fear of reprisal, even when concerns prove unfounded.

Policy Effective Date: 10/06/2025
Next Review Date: 10/06/2026
Policy Owner: Kinisis Solutions HR Dpt

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This policy reflects Kinisis Solutions' unwavering commitment to ethical business practices and human rights protection. Regular review ensures continued effectiveness and alignment with evolving best practices and regulatory requirements.