Whilst Kingsfield does not itself meet the £36 million turnover requirement for publishing a statement, Kingsfield was acquired by a large IT company (GBM Digital Technologies Group Limited) in December 2021, and is therefore adopting its policies and processes as part of the acquisition, which includes its Modern Slavery policies and processes.
PURPOSE
The Modern Slavery Act 2015 came in to force on the 29th of October 2015, with the aim of reducing and preventing modern slavery and human trafficking. All commercial organisations operating in the UK, with a turnover of £36 million or greater are required to publish, or make available, a Modern Slavery and Human Trafficking Statement. Every organisation’s Modern Slavery and Human Trafficking Statement must be reviewed, updated, and re-published each financial year.
This statement sets out Kingsfield’s actions to understand all potential modern slavery risks related to its business, and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.
SCOPE
This statement relates to actions and activities during the financial year. As part of it’s operations to provide ICT hardware and services to consumers, businesses, educational establishments, charities, and public sector bodies, Kingsfield recognises that it has a responsibility to take a robust approach to preventing modern slavery and human trafficking. Kingsfield is absolutely committed to preventing slavery and human trafficking in all of its activities, and to ensuring that its supply chains are free from slavery and human trafficking.
ORGANISATIONAL STRUCTURE
Kingsfield Computer Products Limited (company reg: 3357539) is a wholly owned subsidiary of GBM Digital Technologies Group LTD (company reg: 12470566).
GBM Digital Technologies LTD (company reg: 02719704) is also wholly owned subsidiary of GBM Digital Technologies Holdings LTD (company reg: 07355195), which in turn is a subsidiary of GBM Digital Technologies Group LTD (company reg: 12470566).
Note: GBM Digital Technologies LTD also trades as Sync.
Kingsfield is an ICT hardware and software reseller, and services provider. Kingsfield provides technology-oriented products and services to consumers, businesses, educational establishments, charities, and public sector bodies.
Kingsfield operate in the UK only, and supply within the UK and EU only.
SUPPLY CHAINS
Our supply chains are non-complex, and typically fall in to one of two models:
• Purchasing directly from the manufacturer
• Purchasing from a distributor, who is authorised to distribute goods and services on behalf of the manufacturer
RESPONSIBILITY
Policies: Board of Directors
Risk Assessments: Procurement and Directors regarding supply, HR and Directors regarding employment
Investigations & Due Diligence: Board of Directors
Training: Board of Directors and Head of Operations
RELEVANT POLICIES
Kingsfield operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
Whistleblowing Policy – Kingsfield encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of Kingsfield. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Kingsfield’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
Employee Code of Conduct – Kingsfield’s code makes clear to employees the actions and behaviour expected of them when representing Kingsfield. Kingsfield strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
Supplier Code of Conduct – Kingsfield is currently enhancing its Supplier Code of Conduct, which includes the recent addition of enhanced supplier vetting introduced for all new suppliers – giving Kingsfield greater visibility to those suppliers relevant under the Modern Slavery Act, and their compliance with the act.
The code of conduct outlines Kingsfield’s commitment to ensuring that its suppliers adhere to the highest standard of ethics. Suppliers are required to certify and/or demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour.
Under this commitment, Kingsfield may work with suppliers as necessary to ensure that they meet the standards of the code and improve their worker’s working conditions. Serious violations of the Supplier Code of Conduct, however may lead to sanctions against the supplier, and ultimately, termination of the business relationship.
Further works on policy development and evolution will continue through 2022-23.
RECRUITMENT AND HR POLICY
Last year, Kingsfield continued working toward a more robust Recruitment and HR policy, to include:
• procedures to ensure that Kingsfield only utilises reputable employment agencies to source labour, and verifies the practices of any new agency it is using before accepting workers from them
• working to enhance its processes for ‘eligibility to work in the UK’ (Right to Work) checks for all employees to safeguard against human trafficking or individuals being forced to work against their will
Inline with this commitment, Kingsfield has worked through 2021-22 to fully digitised its HR processes, and enhance its ‘Right to Work’ checks for employees. The digitisation of HR records also allows Kingsfield to more easily audit its records relating to all aspects of its employees, including employment contracts and Right to Work. We will continue to develop our recruitment policy through 2022-23.
DUE DILIGENCE
Over the last year, Kingsfield continued its work in building out a processes to undertake enhanced levels of due diligence when considering taking on new suppliers, and regularly review its existing suppliers, including:
• mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking
• evaluating the modern slavery and human trafficking risks of each new supplier
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping
• conducting supplier audits or assessments, which have a greater degree of focus on
slavery and human trafficking where general risks are identified; and
• invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship
Kingsfield will continue working towards a more robust system, with a view to better assessing and mitigating risk in the supply chain.
ASSESSING RISK
Kingsfield is committed to enhancing existing measures, and introducing new measures to assess and manage the risk of activity carried out across its supply chain. This will form part of our supply chain vetting process, and will take key risk areas in to account, including those associated with:
• Country
• Sector
• Transactions
• Business partnerships
Kingsfield will continue working towards a more robust system.
PERFORMANCE INDICATORS
Kingsfield has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, Kingsfield have:
• made progress in the development of its systems to better handle supplier vetting
• made changes to its recruitment process, utilising a centralised, reputable, and accessible platform for recruitment
• made changes to its mandatory training programmes to include a dedicated Modern Slavery awareness course
We will monitor the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain. The key metric being that no reports are received from employees, our suppliers, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
TRAINING
We are committed to ensuring that our employees are able to recognise, help prevent, and report acts (and suspected acts) of Modern slavery.
Our policies, (i.e. Whistleblowing, and Employee Code of Conduct) are made available to all employees via the staff handbook.
We have also utilised resources provided by the Home Office, and the ‘Anti-Slavery Toolkit’ provided by Nottingham University, to create a mandatory training programme for all staff, with an aim to both:
• raise awareness, and educate our employees about Modern Slavery and Human Trafficking, and
• inform staff about routes and mechanisms for prevention and reporting
BOARD APPROVAL
This statement has been approved by GBM’s board of directors, who will review and update it annually.