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Keystone Employment Group t/a KTB Technologies (“the Company”) is a privately-owned company registered in England and Wales. The Company is carrying on business in the UK Software as a Service market specialising in Workforce Technology. The Company services a wide range of public sector organisations and privately owned businesses in a wide range of sectors/markets. These include but are not limited to: education, healthcare, local and national government, housing, social care, logistics, and charities.
Originally formed as an LLP and with a 40 year heritage, the Company was eventually registered as a Limited Company in 2020. Today it operates out of offices in London and remotely across the UK. The Company currently employs less than 220 people and has a turnover below £36 million each financial year. The Company treats the threat of modern slavery as a matter of the utmost importance and has therefore subscribed to the Modern Slavery Act 2015 on a voluntary basis.
The Company is committed to the highest standards of integrity, transparency, and accountability. It is therefore of vital importance to the Company that it can demonstrate that all appropriate steps are taken to ensure that slavery and human trafficking is not taking place in any of its supply chains or in any part of its own business.
To hold an individual in slavery is a violation of fundamental human rights and a crime. The Company recognises this takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another for the purposes of exploiting them for personal or commercial gain. Accordingly, guidance on how to recognise and respond to the signs of modern slavery is published for the Company’s employees on the Company intranet together with the Company’s Anti-Modern Slavery Policy which sets out how the Company aims to prevent, detect, and report modern slavery in any part of its business or supply chains.
The Company takes a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings and relationships and in implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its UK business operations or in any of the Company’s supply chains. The Company has an HR and Learning & Development consultancy which is responsible for ensuring all Staff training and development needs are met including around the identification and reporting of concerns around modern slavery.
The Company expects the same high standards from its suppliers, contractors and other third parties. As part the Company’s contracting processes, it expects that its suppliers will hold their own suppliers to the same standards set out in our policy statement below.
All staff and third parties are required to raise any concerns about any issue or suspicion of modern slavery in any parts of the Company’s business or supply chains at the earliest possible stage. The Company encourages openness and will support anyone who raises genuine concerns in good faith under its Anti-Modern Slavery Policy, even if they turn out to be mistaken.
The Company is committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of the business or in any of the Company’s supply chains. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. If any staff believe they have suffered any such treatment, the individual is encouraged to inform either Senior Management or the HR Consultancy immediately and to report the matter to the proper authorities.
The board of directors has overall responsibility for ensuring this Company’s Anti-Modern-Slavery and Human Trafficking Policy complies with the Company’s legal and ethical obligations, and that all those Staff and third parties under its control comply with it and has approved this Statement.
1.1 The Company Anti-Slavery Policy applies to all persons working for the Company or on its behalf in any capacity, including employees at all levels, directors, and officers (“Staff”) and third parties including Talent Pool workers, customers, suppliers seconded workers, volunteers, interns, agents, contractors, external consultants (“third parties”).
2.1 To hold an individual in slavery is a violation of fundamental human rights and a crime. The Company recognises this takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another for the purposes of exploiting them for personal or commercial gain.
2.2 The Company takes a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings and relationships and in implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its UK business operations or in any of the Company’s supply chains. The Company expects the same high standards from its suppliers, contractors and other third parties. As part the Company’s contracting processes, it expects that its suppliers will hold their own suppliers to the same standards set out in The Company Anti-Slavery Policy.
2.3 The Company fully supports all national and international efforts to promote ethical principles and work practices and in particular the efforts to prevent exploitation and abuse associated with modern slavery and human trafficking.
2.4 The board of directors has overall responsibility for ensuring the Company Anti-Slavery Policy complies with the Company’s legal and ethical obligations, and that all those Staff and third parties under its control comply with it.
2.5 The Company Anti-Slavery Policy does not form part of any employee’s contract of employment and the Company may amend it at any time.
3.1 The Company Anti-Slavery Policy escribes how the Company will prevent, detect, and report modern slavery in any part of its business or supply chains.
3.2 The Company aims to encourage openness and will support anyone who raises genuine concerns in good faith under the Company Anti-Slavery Policy even if they turn out to be mistaken. The Company is committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of the business or in any of the Company’s supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If any staff believe they have suffered any such treatment, the individual should inform either Senior Management or the HR Consultancy immediately. If the matter is not remedied, an employee should raise it formally in accordance with the Company Grievance Procedure, which is published on the intranet.
4.1 All staff and third parties must comply with the Company Anti-Slavery Policy and avoid any activity that might lead to, or suggest, a breach of the Policy.
4.2 All staff and third parties are required to raise any concerns about any issue or suspicion of modern slavery in any parts of the Company’s business or supply chains of any supplier tier at the earliest possible stage.
4.3 If any Staff believe or suspect a breach of the Company Anti-Slavery Policy has occurred or that it may occur the individual must notify either Senior Management, the HR Consultancy or the Legal Consultancy as soon as possible.
4.4 If Staff are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of the Company’s supply chains constitutes any of the various forms of modern slavery, this should be raised as set out in paragraph 5.3.
4.5 All managers are responsible for ensuring that the Company Anti-Slavery Policy and the Company’s zero-tolerance approach to modern slavery is communicated to all employees and for ensuring those individuals reporting to them understand and comply with The Company Anti-Slavery Policy and are given adequate and regular training as applicable on the policy and the issue of modern slavery in supply chains.
4.6 Management have day-to-day responsibility for implementing the Company Anti-Slavery Policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
4.7 All managers who are responsible for procurement of goods and / or services must ensure that the Company Anti-Slavery Policy and the Company’s zero-tolerance approach to modern slavery is communicated to all third parties during the procurement process and / or at the outset of each business relationship.
4.8 Any employee who breaches the Company Anti-Slavery Policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct and/or referral to the authorities.
5.1 The Company procures the services of certain UK based suppliers, an up-to-date list of which is retained by the Accounts team overseen by the Chief Finance Officer. These suppliers provide a range of goods and services to assist the Company’s business, including IT and other professional services such as legal and accountancy and stationery supplies. As part of its due diligence when procuring services, the Company requires each supplier to comply with relevant legislation.
5.2 The Company supplies its services into the sectors listed in point 2.1 of the Company Anti-Slavery Policy. It does not experience regular seasonal surges in demand except in education where activity drops significantly during holiday periods.
5.3 The Company includes a provision in its standard terms of business with its clients in which each party warrants to the other that it takes all reasonable steps to prevent the exploitation and abuse associated with modern slavery and human trafficking.
5.4 The Company may terminate its relationship with other third parties if they breach the Company Anti-Slavery Policy. Review of the policy – Legal Consultancy has overall responsibility for reviewing the Company Anti-Slavery Policy.
6.1 The Company engages an external Training and Development provider ensuring all Staff training and development needs are met. The training provided includes sales and business development courses, people management courses, compliance training, discrimination and equal opportunities training, bribery and corruption training and many other ad hoc courses relating to specific employee or discipline requirements.