This Modern Slavery and Human Trafficking Statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (“the Act”) relating to Transparency in Supply Chains. Kinovo plc (“Kinovo”) (“Company”) recognises that it has a responsibility to take a robust approach to slavery and human trafficking and we do not tolerate any form of modern slavery or human trafficking in any part of our business.
Kinovo and its subsidiaries acknowledge global responsibility, we are committed to driving out acts of modern slavery. We are taking the appropriate steps to ensure that everyone who works for Kinovo benefits from a working environment in which their fundamental human rights are respected and anyone that we do business with is expected to also uphold these principles. We ensured that our robust controls operated effectively and developed our approach to make certain that, despite the continued disruption caused by COVID-19, we identified any risks and mitigated as appropriate.
This is our third statement, published in accordance with the Act, setting out the steps we’ve taken during the financial year ending 31 March 2022, to identify and prevent modern slavery in our business. We will continue to review the statement and update it annually in accordance with the Act.
Kinovo, via its subsidiaries, is an established and award-winning provider of gas and electrical installation, maintenance and general building services to local authority and housing associations.
Kinovo is the parent company of the Kinovo group of companies (the “Kinovo Group”). The Kinovo Group has over 225 employees and operates solely in the UK with its head office in Chingford.
Kinovo, formerly known as Bilby, was formed in 2015 with a strategy to acquire businesses in the gas, electrical and general building services sectors to meet the continued demand for high-quality improvement and maintenance services in public sector housing. Kinovo is now considered a leading UK provider of specialist property services centred on safety and regulatory compliance, home and community regeneration and suitable living through the installation of efficient and greener energy alternatives.
Kinovo’s reputation for operational excellence and total customer service is underpinned by its disciplined focus on predominantly servicing customers in the London and South-East region.
OUR POLICY ON SLAVERY AND HUMAN TRAFFICKING
We recognise the interdependence of culture and controls and believe that we can achieve more, if our people, business partners and suppliers understand the importance of their roles and take individual and collective responsibility in helping to eliminate the risk of modern slavery.
Kinovo remains committed to adopting a proactive approach to ensuring that there is no modern slavery, human trafficking or hidden labour exploitation in its supply chain or in any part of its business with a zero tolerance for non-compliance. Failure to comply with our policy by employees may result in disciplinary action up to and including summary dismissal, and by contractors or other third parties working with and on our behalf, in termination of contract.
This statement reflects the commitment to acting ethically and with integrity in all of the Kinovo Group’s business relationships and implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in the supply chains.
Kinovo’s suite of internal and external policies set out our expectations and requirements and ensure that business is conducted to the highest ethical standard. We monitor performance and take appropriate action where we believe our people, business partners or suppliers do not meet our high standards.
The most relevant documents include:
- The Company’s Employee Handbook, which covers a range of ethical and conduct-related policies
- Equality & Diversity Policy
- Health and Safety Policy
- Corporate Social Responsibility Policy
- Environmental Policy
- Residents and Customers with Special Needs Code of Conduct
- Equal Opportunities Policy
Kinovo has an effective grievance and whistleblowing policy in place to manage any concerns within the business or its supply chain. These policies are reviewed annually to ensure that they are fit for purpose. All new and existing Kinovo employees are provided with, and have access to, a copy of the latest whistleblowing policy.
Overall responsibility for modern slavery reviews sits with our Board and our Modern Slavery Statement is signed off by Board resolution.
OUR SUPPLY CHAINS
At Kinovo, we recognise that our supply chain is critical to our success. We, therefore, seek to build lasting relationships, treating our suppliers fairly and paying promptly. We want to work with suppliers who share our values and support us in delivering our purpose. We are committed to working with our supply chain to ensure that together we can achieve wider social, economic and environmental benefits.
We use a variety of methods to undertake due diligence on each of our suppliers and ensure that we work with organisations that share our commitment to the highest possible business and ethical standards. This allows us to make informed decisions about who we want to work with. Where we are satisfied that it is a supplier that we want to engage with, we then negotiate appropriate terms with them. To the extent that our suppliers do not adhere to our standards, there can be material consequences, including the termination of our relationship with them.
Kinovo assesses compliance within its existing supply chain and will assess any new suppliers for compliance with the following criteria:
- no forced labour or human trafficking is practised, and employment is freely chosen;
- working conditions are safe and hygienic;
- working hours are not excessive;
- a fair wage is paid;
- no harsh, cruel or degrading practices are allowed; and
- no discrimination is practised.
A failure to comply with the above is an absolute bar to pre-qualification as a supplier to Kinovo.
OUR SUPPLIER DUE DILIGENCE PROCESS
Recognising that the greatest risk of modern slavery is in our supply chains, we continue to take steps to ensure that those are both regulated and reviewed. We undertake initial due diligence before deciding whether to enter into a contract with suppliers, including, but not limited to the following:
- we review our risk assessment for suppliers, both for direct and indirect suppliers through our extended supply chain. We continue to develop our systems and controls for supplier engagement;
- we provide ongoing monitoring of our suppliers, risk rating them using a country and sector risk segmentation tool that considers the product or service being offered together with any slavery risk; and
- where necessary, suppliers are subject to additional scrutiny in the form of on-site visits from a third-party assessor reviewing human rights, labour, and health and safety practices.
TRAINING, RECRUITMENT & COMMUNICATION
To make employees aware of the Act and the drivers of modern slavery, as well as the possible indicators, we share this statement with all employees through our internal communication channels and a copy of this statement is available on the Kinovo website (https://www.kinovoplc.com/).
Our people play a key role in mitigating risk within our business and supply chains, and we recognise that appropriate and targeted training is essential. Kinovo introduced a Groupwide intranet which is also used to facilitate modern slavery and human trafficking training. This reminds our people of our obligations and expectations, including respecting human rights.
Our recruitment processes are transparent and reviewed regularly. Kinovo undertakes pre-employment screening that includes identity checks and confirmation of entitlement to work in the UK on all employees prior to commencing employment with the Kinovo Group.
As part of the onboarding process at Kinovo, each employee is given an overview of the essential policies and information in relation to those policies, procedures and other matters such as whistleblowing.
KEY PERFORMANCE INDICATORS (“KPIs”)
Consideration is currently being given to the key performance indicators that Kinovo may choose to use in tracking our progress in reducing modern slavery risks. The indicators we choose will help to deliver an increase in awareness, especially within our key supply chains and amongst site operative teams.
These key performance indicators are likely to include modern slavery and human trafficking rates amongst our employee base.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Kinovo’s slavery and human trafficking statement for the financial year ending 31 March 2022. This statement applies to Kinovo plc and all of its subsidiary companies and has also been approved by the Boards of Directors of the following members of the Kinovo group companies on today’s date:
- Kinovo plc
- Bilby Limited (Dormant)
- P&R Installation Company Limited
- Purdy Contracts Limited
- Spokemead Maintenance Limited
- Dunham (UK) Limited