Anti-Slavery & Compliance Lead

Kovacs Group Ltd recognises that slavery and human trafficking remains a violation of an individual’s basic human rights. Our aim is to identify our responsibility by alerting staff to the risks, however small, in our business.

Through our whistleblowing policy which is linked to The Modern Slavery Act 2015, all employees are encouraged to report to the senior management team any concerns relating to unlawful conduct or any other matter which is deemed serious. The senior management team will discuss the information received to investigate and take appropriate action.

We are committed to ensuring that there is no modern-day slavery or human trafficking in any part of our business. Our Modern-Day Slavery Policy Statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chain.

This Policy considers and supports some of our other policies: Corporate Social Responsibility, Anti-Bribery, and Whistle-blowing. Formal procedures concerning slavery and human trafficking have been established, including disciplinary procedures where they are breached. Additional procedures ensure that this policy is understood and communicated to all levels of the company, and that it is regularly reviewed by the Director to ensure its continuing suitability and relevance to company activities.

Kovacs Group Ltd will achieve these aims by our initiative to identify and mitigate risk in the following ways (but not limited to):

• Stringent vetting and investigation of our supply chain processes.
• Audit & review our practices regularly to check all our employees are paid at least the minimum wage and have the correct right to work.
• We encourage the reporting of concerns and the protection of whistle-blowers.
• We will not knowingly support or deal with any business involved in slavery or human trafficking.
• We have a zero tolerance to slavery and human trafficking, and we expect all of those in our supply chain and contractors to comply with our values.

Training:

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to all our employees. Our employees have access to our policies and processes on request. We regularly update our policies to incorporate new contracts and new legislation to ensure all our employees (including senior management) are always fully up to date.

Measuring our performance:

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 or supply chains:

• Completion of audits by Directors.
• Use of labour monitoring.
• Compliance monitoring and payroll systems.
• Onboarding audit checklist before contracts are signed.

We have strict policies and procedures in place to ensure the consistent monitoring of our workforce for the signs of human trafficking and labour exploitation. These checks are paramount to allowing us to investigate and identify exploitation at the earliest possible stage.

From the moment a potential worker chooses to join Kovacs Group Ltd, the checks begin. These continue throughout the worker’s time with us. At the time of registration, the identification and ‘right to work’ checks are conducted. This ensures that the worker has control of their own documentation and that their job expectations are managed effectively. All employees meet with a Kovacs Group Team member face-to-face to make sure that they have freely chosen to attend.

In addition, throughout the registration and interview process, all application forms are checked and verified as being the applicant’s own information. We also ask where they found out about Kovacs Group Ltd and the role. Worker education begins at the induction stage, giving an insight into Modern Slavery. It explains why it is illegal in the UK and what the worker should do if they suspect it is happening to a colleague or they are a victim themselves. Literature is available to all workers which includes contact details for the relevant authorities who can assist.

During their employment, regular checks are conducted on workers’ welfare. We use additional avenues of recruitment, such as other recruitment agencies supplying labour into Kovacs Group Ltd, whether based in the UK or overseas, ensuring that these are licensed by the Gangmasters and Labour Abuse Authority (GLAA) and remain compliant against the GLAA’s standards.

We are totally committed to Compliance and Ethical Standards and strive to operate best practices at all times. Everyone in the Company is introduced to our company compliance standards and operating procedures at the start of their employment. Everyone is given the tools to identify the indicators of human trafficking and forced labour, and the reporting channels are very clear for any points of concern. If any exploitation issue may arise, it is urgently flagged to the appropriate authorities to investigate with the full co-operation of Kovacs Group Ltd supporting throughout the case.

We are confident that we have the right checks in place to minimise the risk of human trafficking and labour exploitation taking place within our supply chain. However, should our business be infiltrated, we are able to react quickly and efficiently to resolve every case, every time. This response is due to the knowledge and experience held within the Compliance team, the awareness levels of the wider team members, and the relationships we hold with the relevant government authorities.

Kovacs Group are also committed to reviewing our policy and good practice annually.