Optimum Health Ltd (Trading as ‘Kinhub’) is committed to preventing modern slavery and human trafficking in all aspects of its operations and supply chains. This policy outlines our approach to identifying, preventing, and addressing risks related to modern slavery and human trafficking.
Modern Slavery: Practices including slavery, servitude, forced and compulsory labour, and human trafficking, as defined by the Modern Slavery Act 2015.
Human Trafficking: The recruitment, transportation, transfer, harbouring, or receipt of persons by means of threat, force, coercion, abduction, fraud, or deception for the purpose of exploitation.
Kinhub is dedicated to maintaining the highest ethical standards and ensuring that all our business activities are free from modern slavery and human trafficking. We are committed to:
Complying with all applicable laws and regulations related to modern slavery and human trafficking.
Conducting business in an ethical, transparent, and responsible manner.
Oversee the implementation and enforcement of this policy.
Ensure adequate resources are available to address modern slavery risks.
Promote awareness of modern slavery and human trafficking within their teams.
Ensure compliance with this policy in their respective areas of responsibility.
Report any concerns regarding modern slavery or human trafficking.
Adhere to the principles and guidelines outlined in this policy.
Kinhub will conduct thorough due diligence to identify and mitigate modern slavery risks within our operations and supply chains. This includes:
Risk Assessment: Regularly assessing the risk of modern slavery in our operations and supply chains.
Supplier Vetting: Ensuring all suppliers and contractors comply with our ethical standards and legal obligations.
Contracts: Including modern slavery clauses in contracts with suppliers and contractors to ensure compliance.
Kinhub will provide the following specific training and resources to ensure employees understand their roles in prevention:
Mandatory Training Programmes: Implementation of mandatory sessions for all employees, including new hires during onboarding.
Tailored Content: Adjusting training for specific roles (e.g., senior managers and procurement staff) including e-learning modules on indicators of slavery and reporting procedures.
Workshops and Seminars: Conducting sessions to discuss issues, share best practices, and analyse real-life case studies.
Resource Materials: Distribution of guides, checklists, and reference documents that reflect current legislation and best practices.
Kinhub encourages the reporting of any concerns. To ensure an effective whistleblowing mechanism, we implement the following measures:
Clear Communication Channels: Providing multiple, easily accessible channels, including a secure online reporting system and an anonymous email address.
Anonymity and Confidentiality: Using secure technology and data protection measures to safeguard the identity of the whistleblower.
Non-Retaliation Policy: Implementing a strict policy to protect whistleblowers from discrimination or negative consequences.
Independent Oversight: Assigning an independent individual or team to manage the mechanism and ensure impartial investigations.
Feedback and Improvement: Providing updates on the status of reports where appropriate and using case data to identify and close gaps in the mechanism.
Kinhub will regularly monitor the effectiveness of this policy through:
Annual Review: Conducting a yearly review of the policy and its implementation.
Performance Indicators: Developing key performance indicators (KPIs) to measure the effectiveness of our anti-slavery efforts.
Kinhub is committed to enhancing our response to risks through stakeholder engagement:
Supplier Engagement: Distributing a Supplier Code of Conduct and conducting regular audits. Providing training to suppliers where necessary.
Employee Involvement: Encouraging staff to participate in external networks and events related to modern slavery.
Collaboration with External Experts: Inviting experts to conduct training sessions, audits, and policy reviews.
Stakeholder Forums: Organising roundtables with suppliers, customers, and community representatives to collaboratively develop solutions.
Public Reporting: Publishing an annual Modern Slavery Statement on the Kinhub website to demonstrate transparency.
Innovation: Exploring new technologies and methodologies to improve detection and prevention efforts.
This policy has been approved by the Board of Directors and will be reviewed annually. It is published on our website and available to all employees and stakeholders.
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