Modern Slavery & Human Trafficking Statement

Introduction

This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 05 April 2023.

Kudu Spectrum Ltd (‘the Company’, ‘we’, ‘us’ or ‘our’) is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values.

Organisational Structure

Kudu Spectrum Ltd and has business operations in the United Kingdom.

We operate in the health sector. The nature of our supply chains is as follows:

We work with a number of key direct suppliers who provide goods, such as medical equipment and devices, which we provision for our customers.

For more information about the Company, please visit our website: https://www.kuduspectrum.co.uk/.

Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner.

These include the following:

  • Recruitment and selection policy –

We conduct checks on all prospective employees to verify that they are eligible to work in the UK. Certain roles require a Disclosure and Barring Service (DBS) check where employees may be working with vulnerable people.

  • Supplier code of conduct –

We operate this policy to ensure our suppliers operate in full compliance with the laws, rules and regulations of the countries in which they operate, and to seek similar commitments across their own supply chain.

  • Staff code of conduct-

We are committed to the fair treatment of all staff. Our staff code of conduct reflects our core values and expected behaviours. The code of conduct makes it clear that we have a zero-tolerance approach to modern slavery.

  • Procurement policy –

We want to make sure that potential suppliers are committed to ensuring that slavery and human trafficking is not taking place within their own supply chains. Our procurement policy and supporting procedures set out controls and checks undertaken to help verify this.

We make sure our suppliers are aware of our policies and adhere to the same standards.

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:

  • Internal supplier audits.
  • External supplier audits.

Our due diligence procedures aim to:

  • Identify and action potential risks in our business and supply chains.
  • Monitor potential risks in our business and supply chains.
  • Reduce the risk of slavery and human trafficking occurring in our business and supply chains.

Risk and Compliance

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its supply chain through:

  • Evaluating the slavery and human trafficking risks of each new supplier.
  • Creating an annual risk profile for key suppliers.
  • Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping.

We consider that we operate in a high-risk environment because the majority of our supply chain is based in China and in high-risk industries, such as the large-scale manufacture of products in factories.

We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will seek to terminate our relationship with that supplier immediately.

Effectiveness

The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPIs are as follows:

  • We will contact suppliers to enquire about their modern slavery practices every 12 months.
  • We will train our staff about modern slavery issues and increase awareness within the Company.

The statement was approved by the board of directors.

Robert Hutchins, Director Kudu Spectrum Ltd

Date: 20/02/2024

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