Modern Slavery Policy

Previous Modern Slavery Act Statement

Introduction

We do not tolerate modern slavery or human trafficking in our organisation or in our supply chain. This statement sets out the steps that we have taken to eliminate, as far as possible, the risk of modern slavery and human trafficking taking place.

Kondor is committed to ensuring that all of its business dealings are carried out in full compliance with relevant laws and, in doing so, we endorse the implementation and promotion of ethical business practices to protect workers from being abused and exploited both within Kondor and its supply chains. We know that slavery, servitude, forced labour and human trafficking (Modern Slavery) is a global and growing issue given the rapid rise in global migration, existing in every region in the world and in every type of economy, whether industrialised, developing or in transition. No sector or industry can be considered immune or untainted. Kondor has a zero tolerance approach to Modern Slavery of any kind within our operations and supply chain. We all have a responsibly to be alert to the risks, however small, in our business and in the wider supply chain.

Staff are expected to report concerns, using the appropriate reporting channels, and management are expected to act upon them. Our product supply chains are extensive and global, with many suppliers in many countries. Policies and contractual controls, and internal policies include our Corporate & Social responsibility policy, our Code of Ethics where we confirm that we will not tolerate any allegations that human rights are not properly respected. We also operate a Whistleblowing Policy, aimed principally at our employees but also available to others working in our supply chains which encourages staff to report any wrongdoing which extends to human rights violations like Modern Slavery.

DUE DILIGENCE PROCESSES FOR MODERN SLAVERY AND HUMAN TRAFFICKING

As part of our initiative to identify and mitigate the risk of human slavery and human trafficking in our supply chains, we conducted a review of suppliers
While we are confident that there is no modern slavery or human trafficking taking place within our direct organisation following this assessment (due in part to our internal checking process and the skill level of employees we typically engaged), parts of our supply chains in certain areas,
Such as in our suppliers in the Far East, do pose a medium risk because suppliers in these areas may rely on seasonal, low paid and low skilled workers. In any instances where we felt there was such a risk, we contacted our existing suppliers in writing, reminding them of our values and ethical standards, and reiterating the expectations we have when working with them.

We have also implemented systems to:

  • Identify and assess potential risk areas in our supply chains – no new supplier will be appointed without them going through our risk assessment.
  • Mitigate the risk of modern slavery and human trafficking occurring in our supply chains, which we manage through our new-supplier process and our contracts which will, going forward, give us the ability to monitor our supply chains and potential risk areas.
  • Monitor potential risk areas in our supply chains.

SUPPLIER ADHERENCE TO OUR VALUES AND ETHICS

We do not tolerate modern slavery and human trafficking. We have put in place a new supplier process which will both
(i) assess the risk of modern slavery and human trafficking in any new supplier and its own supply chains before we engage with that supplier and
(ii) give us the ability to monitor and audit suppliers once they have been engaged
(iii) Our QC and Product Teams conduct regular AD-HOC factory and supplier visits

TRAINING & AWARENESS

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and in our supply chains, we will be asking our business partners to provide training and awareness to their staff and suppliers.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Company’s modern slavery and human trafficking statement for the financial year ending 31st Dec 2016.