INTRODUCTION 

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 we continue to identify any  risks and mitigate as appropriate. 

This is our fourth statement, published in accordance with the Act, setting out  the steps we’ve taken during the financial year ending 31 March 2023, 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. 

ORGANISATIONAL STRUCTURE 

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. 

OUR BUSINESS 

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.

GOVERNANCE 

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 
  • R. Dunham (UK) Limited 

David Bullen 
CEO 
Kinovo plc