INTRODUCTION

This Modern Slavery and Human Trafficking Statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (“the Act”) relating to Transparency in Supply Chains. Kinovo plc (“Kinovo”) (“Company”) recognises that it has a responsibility to take a robust approach to slavery and human trafficking. We do not tolerate any form of modern slavery or human trafficking in any part of our business.

We are taking the appropriate steps to ensure that everyone who works for Kinovo benefits from a working environment in which their fundamental human rights are respected. Any other party that we do business with is expected to also uphold these principles. Our robust controls have operated effectively in the financial year ending 31 March 2024 and we have developed our approach to ensure that we continue to identify and mitigate risks.

This is our fifth statement, published in accordance with the Act. This sets out the steps we have  taken during the financial year ending 31 March 2024 to identify and prevent modern slavery in our business. We will continue to review the statement and update it annually in accordance with the Act.

ORGANISATIONAL STRUCTURE

Kinovo, through its subsidiaries, is an established and award-winning provider of specialist property services Group that delivers compliance and sustainability solutions to local authority and housing associations.

Kinovo is the parent company of the Kinovo group of companies (the “Kinovo Group”). The Kinovo Group has over 255 employees and operates solely in the UK with its head office in Chingford.

OUR BUSINESS

Kinovo, formerly known as Bilby, was formed in 2015  as a holding company to provide a platform for strategic acquisitions in the mechanical, electrical and general building services industries to meet the continued demand for high-quality improvement and maintenance services in public sector housing. Kinovo is now considered a leading UK provider of specialist property services centred on safety and regulatory compliance, home and community regeneration and suitable living through the installation of efficient and greener energy alternatives.

Kinovo’s reputation for operational excellence and total customer service is underpinned by its disciplined focus on servicing customers in London and South-East England.

OUR POLICY ON SLAVERY AND HUMAN TRAFFICKING

We recognise the interdependence of culture and controls and believe that we can achieve more if our people, business partners and suppliers understand the importance of their roles and take individual and collective responsibility in helping to eliminate the risk of modern slavery.

Kinovo is committed to adopting a proactive approach to ensuring that there is no modern slavery, human trafficking or labour exploitation in its supply chain or in any part of its business, and there is a zero tolerance for non-compliance. Failure to comply with our policy by employees may result in disciplinary action up to and including summary dismissal, and by contractors or other third parties working with and on our behalf, in termination of contract.

This statement reflects the commitment to acting ethically and with integrity in all of Kinovo’s business relationships and implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in the supply chains.

Kinovo’s suite of internal and external policies set out our expectations and requirements and ensure that business is conducted to the highest ethical standards. We monitor performance and take appropriate action where we believe our people, business partners or suppliers do not meet our high standards.

The relevant policies and procedures include:

  • The Company’s Employee Handbook, which covers a range of ethical and conduct-related policies
  • Equality & Diversity Policy
  • Health and Safety Policy
  • Corporate Social Responsibility Policy
  • Environmental Policy
  • Residents and Customers with Special Needs Code of Conduct 
  • Equal Opportunities Policy
  • Anti-Bribery and Corruption Policy

These policies are reviewed annually to ensure that they are fit for purpose.

Kinovo has an effective grievance and whistleblowing policy in place to manage any concerns within the business or its supply chain. All new and existing Kinovo employees are provided with, and have access to, a copy of the latest whistleblowing policy.

GOVERNANCE

Overall responsibility for modern slavery reviews sits with our Board. Our Modern Slavery Statement is reviewed and signed off by Board resolution on an annual basis.

OUR SUPPLY CHAINS

At Kinovo, we recognise that our supply chain is critical to our success. We therefore seek to build lasting relationships and treat our suppliers fairly. We want to work with suppliers who share our values and support us in delivering our purpose. We are committed to working with our supply chain to ensure that together we can achieve wider social, economic and environmental benefits.

We use a variety of methods to undertake due diligence on each of our suppliers and ensure that we work with organisations that share our commitment to the highest possible business and ethical standards. This allows us to make informed decisions about who we want to work with. We will only begin to negotiate appropriate terms with suppliers when we find that they meet our high standards of business conduct.  To the extent that our suppliers do not adhere to our standards, there can be material consequences, including the termination of our relationship with them.

Kinovo assesses compliance within its existing supply chain and will assess any new suppliers for compliance with the following criteria:

  • no forced labour or human trafficking is practised, and employment is freely chosen;
  • working conditions are safe and hygienic;
  • working hours are not excessive;
  • a fair wage is paid;
  • no harsh, cruel or degrading practices are allowed; and 
  • no discrimination is practised.

A failure to comply with the above is an absolute bar to pre-qualification as a supplier to Kinovo.

OUR SUPPLIER DUE DILIGENCE PROCESS

Recognising that the greatest risk of modern slavery is in our supply chains, we continue to take steps to ensure that those are regulated and reviewed.

We undertake initial due diligence before deciding whether to enter into a contract with suppliers, including, but not limited to the following:

  • we review our risk assessment for suppliers, both for direct and indirect suppliers through our extended supply chain. We continue to develop our systems and controls for supplier engagement;
  • we provide ongoing monitoring of our suppliers, risk rating them using a country and sector risk segmentation tool that considers the product or service being offered together with any slavery risk; and
  • where necessary, suppliers are subject to additional scrutiny in the form of on-site visits from a third-party assessor reviewing human rights, labour, and health and safety practices.
TRAINING, RECRUITMENT & COMMUNICATION

To make employees aware of the Act and the drivers of modern slavery, as well as the possible indicators, we share this statement with all employees through our internal communication channels and a copy of this statement is available on the Kinovo website (https://www.knold.beechdev.co.uk/).

Our people play a key role in mitigating risk within our business and supply chains, and we recognise that appropriate and targeted training is essential. Kinovo operates a Group- wide intranet which is also used to facilitate modern slavery and human trafficking training. This reminds our people of our obligations and expectations, including respecting human rights.

Our recruitment processes are transparent and reviewed regularly. Kinovo undertakes pre-employment screening that includes identity checks and confirmation of entitlement to work in the UK on all employees prior to commencing employment with the Kinovo Group.

As part of the onboarding process at Kinovo, each employee is given an overview of the essential policies and information in relation to those policies, procedures and other matters such as whistleblowing.

KEY PERFORMANCE INDICATORS (“KPIs”)

Consideration is currently being given to the key performance indicators that Kinovo may choose to use in tracking our progress in reducing modern slavery risks. The indicators we choose will help to deliver an increase in awareness, especially within our key supply chains and amongst site operative teams.

These key performance indicators are likely to include modern slavery and human trafficking rates amongst our employee base.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Kinovo’s slavery and human trafficking statement for the financial year ending 31 March 2024. This statement applies to Kinovo plc and all of its subsidiary companies and was approved by the Boards of Directors of the following members of the Kinovo group companies on 7 November 2024:

  • Kinovo plc
  • Bilby Limited (Dormant)
  • P&R Installation Company Limited
  • Purdy Contracts Limited
  • Spokemead Maintenance Limited
  • R. Dunham (UK) Limited

David Bullen
CEO
Kinovo plc