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    Part of Kin + Carta

    Prishtina: Bekim Fehmiu Str., Arting Building, 5th Floor, 10000, Pristina, Kosovo

    Sofia: 20 Kosta Lulchev St., 3rd floor 1113 Sofia, Bulgaria

    Skopje: Zum Palace, 32 1737 St., 1st floor
    1000 Skopje, North Macedonia

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    Modern slavery act

    Policy statement


    Introduction

    Kin and Carta plc and its subsidiaries (hereinafter referred to as ‘Kin and Carta’), are committed to acting responsibly and ethically when conducting business.

    The term “Modern Slavery” which includes Slavery, forced labour and human trafficking is a violation of fundamental human rights. Modern Slavery is a global issue and one of the most widespread crimes in the world. Child Labour is another world wide issue, where children are being deprived of their childhood, education and dignity. Children are engaged in work that may be dangerous or may cause them harm mentally, physically, socially or morally. We at Kin and Carta believe that every child deserves the rights set out in The United Nations Convention on the Rights of the Child “UNCRC”. Therefore, we have a zero tolerance policy toward any form of Modern Slavery or Child Labour.

    Our values, which are: “to be deeply connected, instinctively compassionate and always courageous”, provide a supportive organisational culture to ensure we can conduct our business practices responsibly so that our employees can confidently raise any concerns to help prevent Modern Slavery or Child Labour. Kin + Carta’s “Speak Up'' policy for whistleblowing is available to all employees and is reviewed annually. In addition a whistleblowing guide is available for employees to explain how to raise or highlight any concerns using the appropriate reporting channels so that management acts on those concerns accordingly.

    Our business

    Kin and Carta is a London Stock Exchange-listed global digital transformation consultancy committed to working alongside clients to build a world that works better for everyone.

    Kin and Carta's 1,700 strategists, engineers, and creatives around the world bring the connective power of technology, data, and experience to the world's most influential companies - helping them to accelerate their digital roadmap, rapidly innovate, modernise their systems, enable their teams, and optimise for continued growth. Headquartered in London and Chicago with offices across three continents, the border-less model of service allows for the best minds to be connected to collaborate on client challenges.

    With purpose at its core, Kin and Carta became the first publicly-traded business on the London Stock Exchange to achieve B Corp certification as a PLC. It meets the highest standards of verified social and environmental performance, public transparency, and accountability to balance the triple bottom line of people, planet, and profit.

    Our supply chains

    Due to the nature of our business, most of our companies have relatively straightforward direct supply chains, with the majority of products and services sourced from suppliers based in the European Union, United States, United Kingdom and Latin America. However, some of our company's suppliers may have extensive supply chains (however, predominantly our supplier base is software as a service solutions), connecting us with many businesses worldwide.

    We are passionate about doing business responsibly and acting ethically so it is important to us and a necessity that our suppliers share our commitment to human rights and the prevention of Modern Slavery and Child Labour within their enterprise and wider supply chains.

    Managing risk

    We have systems and procedures in place to identify, monitor and mitigate the risk of Modern Slavery and Child Labour occurring in our supply chains. We are also committed to protecting any whistleblowers who bring victims of Modern Slavery or Child Labour to light and/or call out the actions of people that facilitates or conceals these activities.

    These systems are:

    • Our supplier selection and retention processes, which are supported by our Supplier Code of Conduct. Our Supplier Code of Conduct is intended to ensure that all our suppliers comply with our mandatory requirements related to their treatment of employees, health, safety and environment, which sets our expectations of how they will conduct business and the standards of ethical behaviour we expect. It inter alia requires their adherence to comply with all applicable local and international laws and regulations, including the Modern Slavery Act in the UK. Our Supplier Code of Conduct assessments ask our suppliers to confirm that they comply with all applicable human rights and equity laws, and laws prohibiting slavery or human trafficking, and that they adhere to our zero tolerance Modern Slavery policy.
    • Supplier reviews are undertaken on key suppliers within Kin and Carta as part of the global procurement process. In FY22 further processes are being implemented for enhanced supplier diligence procedures, for example with software solutions and developing a system that can track supplier onboarding.
    • Key suppliers are requested to confirm acceptance of our Code of Ethics which requires compliance with applicable Modern Slavery laws and prohibits of any form of child labour and Anti-Corruption and Bribery Policy, these are also mandatory requirements of our the Supplier Code of Conduct.

    We will terminate our relationship with clients, suppliers and other business partners when their business conduct is deemed to be a violation of the Modern Slavery Act or Child Labour laws, including but not limited to the Conventions re Minimum Age Convention, 1973 (No. 138) and Worst Forms of Child Labour Convention, 1999 (No. 182) as set out in International Labour Organization (“ILO”) Fundamental Conventions.

    Our policies

    Kin and Carta will not knowingly do business with any organisation or body involved in Modern Slavery or Child Labour. Our commitment to the Modern Slavery Act 2015 is reinforced by the following policies of Kin and Carta:

    • Code of Ethics
    • Anti-Corruption and Bribery Policy
    • Supplier Code of Conduct
    • Whistleblowing Policy (“Speak Up”)
    • Inclusion, Diversity, Equality and Awareness

    Our people

    We have local Human Resource and Employee Experience functions across Kin and Carta to address employee matters and provide formal recruitment processes, which include pre-employment checks. For our UK based businesses, this includes processes to ensure that employees have the right to work in the United Kingdom and compliance with the National Living Wage.

    Kin and Carta has developed training regarding Modern Slavery which will be disseminated globally which includes the International Labour Organisation (“ILO”) indicators of forced labour such as abuse of vulnerability, deception, restriction of movement, isolation, physical and sexual violence, intimidation and threats, retention of identity documents, withholding of wages, debt bondage, abusive working and living conditions or excessive overtime in order to educate its workforce on key indicators that would warrant urgent investigation. There have been no reports of finding any ILO indicators during the year. The training is designed to help our employees understand Modern Slavery, with a special focus on child labour and child slavery, and Kin + Carta’s zero-tolerance policy toward any form of these acts. It also provides risk factors to identify, as well as the systems to manage risk and how to report concerns related to Modern Slavery.

    Progress over time in addressing Modern Slavery risks

    During the period of the statement Kin and Carta focused on the following priority risks:

    • Risk that employees do not understand key indicators of Modern Slavery or how to report concerns, this risk has been further mitigated by the development of training tools for employees which will be disseminated in FY22.
    • Risk involving due diligence in the operations and supply chains, progress has been made to mitigate this risk by the creation of a centralised procurement team and process.
    • Risk regarding harassment, intimidation and discrimination, we have further mitigated this risk by the creation of a global anti-harassment, discrimination and bullying policy which has been disseminated globally to all employees.

    After a review of the effectiveness of the steps we have taken this year to ensure that there is no known Modern Slavery or human trafficking in our operations, supply chains or customer and client relationships, we intend to take the following further steps to enhance our internal procedures:

    • Disseminate employees training in FY22.
    • Create a standalone policy for Modern Slavery and Child Labour.

    This policy statement concerning slavery and human trafficking is made pursuant to section 54(1) of the Modern Slavery Act 2015 and was approved by the Board of Kin and Carta plc.

    J Schwan
    Chief Executive Officer, Kin and Carta plc

    January 2022