SLAVERY AND HUMAN TRAFFICKING STATEMENT
The Modern Slavery Act 2015 (“the Act”) came into effect on 29th October 2015. This statement, as required under the Act, sets out the steps KBW Ltd (“KBW”), is taking to reduce the risk of slavery and human trafficking taking place in its supply chains or in any part of its business.
This statement applies to KBW and all of its suppliers, regardless of their turnover.
KBW’S SUPPLY CHAINS AND ITS POLICIES ON SLAVERY AND HUMAN TRAFFICKING
KBW’s principle activities include design and creative services that are required in order for it to provide rapid and effective brand activations to its customers. KBW expects the highest standards from all of its suppliers and has put in place various measures to reduce the risk of slavery or human trafficking taking place in its supply chains or in any part of its business.
KBW has put in place an Anti-Slavery and Human Trafficking Policy to reflect its commitment to acting ethically and with integrity in all its business relationships. This includes implementing and enforcing effective systems and controls in order to minimise the risk of slavery and human trafficking taking place anywhere in its business or its supply chains. KBW has also has in place a Whistleblowing Policy so as to ensure employees are able to raise concerns about malpractice or wrongdoing, including in respect of slavery and human trafficking. KBW recognises the importance of enabling employees to speak out if they feel a malpractice is taking place. KBW will continue to monitor both policies, and will update them as required.
KBW’s Responsible Procurement Policy and its Code of Conduct for Business Partners form part of our strategy for social, economic and environmental performance. The Code of Conduct for Business Partners defines KBW’s requirements and principles for all business dealings it has with suppliers, consultants, agents and all other providers of goods and services. It includes specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in servitude, whether adults or children. The Responsible Procurement Policy sets out KBW’s expectations of suppliers and their supply chains, focusing particularly on the United Nations Global Compact’s ten principles. In accordance with its own internal governance procedures, KBW has incorporated both the Code of Conduct for Business Partners and the Responsible Procurement Policy into its contracting processes. KBW expects its suppliers to hold their own suppliers to the same high standards.
KBW’S EFFECTIVNESS IN COMBATING MODERN SLAVERY AND HUMAN TRAFFICKING
KBW operates a risk-based approach to assessing suppliers and subcontractors’ conformance with, and performance against, the ten principles within the United Nations Global Compact. Applying a methodology, which is based around a suppliers’ country of operation and their category of supply, higher risk suppliers have been identified and subjected to (or are currently being subjected to) further assessment. The results of this risk-based assessment procedure will continue to inform and develop KBW’s future risk management plans.
In addition, as part of its initiative to identify and mitigate risks associated with slavery and human trafficking, KBW will continue to advance both its pre contract, and post contract processes and procedures in order to:
· identify and assess potential risk areas in its supply chains;
· mitigate the risk of slavery and human trafficking occurring in its supply chains; and
· monitor potential risk areas in its supply chains.
KBW remains dedicated to strengthening its practices in this area and it will continue to develop further measures, including the training of staff where appropriate, to further reduce the risk of slavery and human trafficking taking place within its own business and across its supply chains.
KBW has zero tolerance to slavery and human trafficking in all its business dealings. KBW is committed to the prevention of slavery and human trafficking in all its forms and will not tolerate or condone it within any part of its business or supply chains.
This statement is made pursuant to section 54(1) of the Act and constitutes KBW’s slavery and human trafficking statement.
EQUALITY AND DIVERSITY
KBW LTD is unreservedly opposed to any form of discrimination on the grounds of age, disability, gender reassignment, marriage or civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation (defined as Protected Characteristics).
Using fair and objective employment practices, the organisation aims to ensure that
- All employees and potential employees are treated fairly and with respect at all stages of their employment.
- All employees (volunteers/service users) have the right to be free from harassment and bullying of any description, or any other form of unwanted behaviour. Such behaviour may come from other employees or by people (third parties) who are not employees of KBW LTD, such as customers or clients.
- All employees (volunteers/service users) have an equal chance to contribute and to achieve their potential, irrespective of any defining feature that may give rise to unfair discrimination.
- All employees (volunteers/service users) have the right to be free from discrimination because they associate with another person who possesses a Protected Characteristic or because others perceive that they have a particular Protected Characteristic, even if they do not.
HEALTH AND SAFETY
The health and safety of our employees and of persons who may be affected by our undertaking is of paramount importance. We aim to provide and maintain safe and healthy working conditions, equipment and systems of work for all our employees and to provide them with the necessary information, instruction and training to achieve this aim.
Our health and safety policy sets out our commitment to planning and managing health and safety.It is the key to achieving acceptable standards, reducing accidents and cases of work-related ill health and is intended to show our employees that we care for their health and safety.
Appropriate preventive and protective measures are, and will continue to be, implemented following the identification of work related hazards and assessment of the risks associated with them.
We recognise the importance of employer/employee consultation on matters of health and safety and the value of individual consultation prior to allocating specific health and safety functions. We also accept our responsibility for the health and safety of others persons who may be affected by our activities.
The provision of adequate resources, allocation of duties and responsibilities for safety matters, the identity of competent persons appointed with particular responsibilities, and the arrangements made to implement this policy are set out herein and/or in associated health and safety documents and records.
KBW adheres to the following principles:
1. Information should be classified in line with the Information Classification Framework and in accordance with any other legislative, regulatory or contractual requirements that might increase the sensitivity of the information and security requirements.
2. All individuals covered by the scope of this policy must handle information appropriately in accordance with its classification level.
3. Information should be only available to those with a legitimate need for access.
4. Information will be protected against unauthorised access and processing.
5. Information will be protected against loss and corruption.
6. Information will be disposed of securely and in a timely manner with measures appropriate for its classification.
7. Breaches of policy must be reported by anyone aware of the breach in a timely manner.
Protection of the environment in which we live and operate is part of KBW’s values and principles and we consider it to be sound business practice. Care for the environment is one of our key responsibilities and an important part of the way in which we do business. The Directors of KBW are committed to reducing the impact of the organisation’s operations on the environment and reducing its carbon footprint.
KBW is committed to:
• Comply with all relevant environmental legislation, regulations and approved codes of practice;
• Protect the environment by striving to prevent and minimize our contribution to pollution of land, air, and water,
• Conserve energy, water, paper and other resources
• Seek to keep wastage to a minimum and maximize the efficient use of materials and resources,
• Manage and disposing of all waste in a responsible manner,
• Reduce waste through re-use and recycling and by using reconditioned and recycled products and materials where such alternatives are available,
• Provide training for our staff so that we all work in accordance with this policy and within an environmentally aware culture and to play a full part in developing new initiatives,
• Regularly communicate our environmental performance to our employees:
• Develop our management processes to ensure that environmental factors are considered during planning and implementation,
• Monitor and continuously improve our environmental performance.