Introduction 

This statement is made pursuant to section 54 of the Modern Slavery Act 2015. It sets out the steps taken by Kingfisher Telecom Ltd and relevant group companies (together, “Kingfisher”) in relation to the prevention of modern slavery and human trafficking in its business during the financial year to reflect this commitment.

Kingfisher is committed to improving its practices to combat slavery and human trafficking in its suppliers, contractors and business partners. It addresses the risks of modern slavery by acting ethically and with integrity in business relationships.

Our Organisation 

Kingfisher is one of UK’s fastest growing telecommunication service providers, delivering broadband, leased line and cloud voice solutions to small and medium sized businesses.

We have around 50+ staff and engaged self-employed field operators, contractors and business partners, most of whom are based in the United Kingdom. Our staff are not in any category which is generally seen to be vulnerable to modern slavery, so our focus is to ensure there are policies and procedures in place in relation to our contractors and business partners.

Due Diligence

Kingfisher carries out due diligence on suppliers in high-risk areas and has developed procedures for accessing those suppliers. This ensures that we only select suppliers who comply with our high standards and policies. 

Kingfisher has an internal team responsible for assessing information and documentation submitted by suppliers. Should a supplier fail or refuse to provide any information required or fail to meet Kingfisher’s expectations, this may result in Kingfisher not entering into a relationship with them or terminating any current relationship. 

Policies 

Our policy is to assess and address the risks of violations of anti-human trafficking and anti-modern slavery laws. We adopt and communicate to our staff procedures that contribute to ensuring modern slavery does not occur in our business or supply chains and we expect organisations with whom we do business to adopt and enforce policies to comply with anti-human trafficking and anti-modern slavery legislation. 

These policies are reviewed and updated regularly and include our whistleblowing policy which encourages staff to report any concerns through multiple channels, including any related to modern slavery/trafficking and child and forced labour.

Our values, which are embedded throughout our business, set the parameters for how we expect our people to behave with colleagues, customers, and others. We seek to treat everyone fairly and consistently, creating a workplace and business environment that is open, transparent and trusted.

In terms of employment, we have robust recruitment processes in line with the UK employment laws, including ‘right to work’ document checks, contracts of employment and checks to ensure everyone employed is 16 and above. We also offer market related pay and wellbeing activities and initiatives to support our staff’s physical and mental wellbeing.

Further steps 

We will continue to review our procurement process and engage with our suppliers. We will provide training on modern slavery to our staff as appropriate.

Supplier adherence to our values

We have zero tolerance to slavery and human trafficking. Our compliance, legal, human resources and provisioning teams all work to ensure our employees, suppliers and contractors comply with our values.

Our effectiveness in combating slavery and human trafficking 

We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business:

KPI 1: Risk Assessment 

We are developing a new onboarding process where we will invite all high-risk suppliers to complete our modern slavery risk assessment.

KPI 2: Commercial Capability 

Ensure that our compliance, legal, human resources and provisioning teams receives access to ongoing updates in respect of business and human rights, specifically modern slavery.

Further steps

We intend to take the following steps to combat slavery and human trafficking:

• Ensure our KPIs function to help us understand whether the action we are taking is working well and where we need to improve.
• Place a stronger emphasis on the management of modern slavery risk in supplier performance review conversations.
• Review new commercial agreement business cases for modern slavery risk management and prevention. 

Approval 

This statement has been approved by the Directors of Kingfisher Telecom Ltd.

Guru Dev SETH

Director of Kingfisher Telecom Ltd

 

© Kingfisher Telecom Ltd 01 September 2022