Modern Slavery & Human Trafficking Policy

1. Policy statement

Kairox Recruitment Limited is committed to conducting all of its business with honesty, integrity, transparency and respect for human rights. We have a zero-tolerance approach to modern slavery, servitude, forced labour, compulsory labour and human trafficking in all aspects of our business and supply chain.

As an Employment Business and Employment Agency, we recognise our responsibility to ensure that all workers supplied by Kairox Recruitment Limited are recruited ethically, treated fairly and engaged in accordance with applicable employment legislation.

We are committed to preventing modern slavery within our own operations, throughout our recruitment processes and, where reasonably practicable, within our supply chain and business relationships.

We expect the same high standards from our clients, suppliers, contractors, business partners and any organisations with whom we work.

Company No: 16537892. Version 1.1. Effective date: 8 July 2026. Review date: 8 July 2027.

2. Purpose

The purpose of this policy is to:

• Prevent modern slavery and human trafficking within our business
• Promote ethical recruitment practices
• Ensure workers are treated fairly and lawfully
• Raise awareness of modern slavery risks
• Provide a clear process for reporting concerns
• Ensure compliance with the Modern Slavery Act 2015

3. Scope

This policy applies to:

• Directors
• Employees
• Temporary workers
• Agency workers
• Contractors
• Consultants
• Suppliers
• Recruitment partners
• Any individual acting on behalf of Kairox Recruitment Limited

4. Our commitment

Kairox Recruitment Limited is committed to:

• Conducting recruitment lawfully and ethically
• Never knowingly engaging in or supporting forced labour or human trafficking
• Verifying, where appropriate, the identity and Right to Work of all workers
• Paying workers in accordance with applicable legislation and contractual agreements
• Promoting fair treatment and equal opportunities
• Working only with organisations that share our commitment to ethical labour practices
• Reviewing our recruitment processes to minimise the risk of exploitation

5. Responsibilities

Company Directors. The Directors have overall responsibility for ensuring this policy is implemented effectively and remains compliant with legal and ethical obligations. They are responsible for:

• Reviewing this policy annually
• Promoting an ethical working culture
• Providing appropriate resources to support compliance
• Ensuring suitable controls are maintained

Recruitment Consultants and Employees. All employees are responsible for:

• Reading and complying with this policy
• Remaining alert to indicators of modern slavery
• Reporting concerns immediately
• Cooperating with any investigation
• Treating all workers fairly and respectfully

Compliance responsibilities. The Recruitment Director is responsible for:

• Monitoring compliance with this policy
• Reviewing recruitment procedures
• Investigating reported concerns
• Maintaining appropriate records
• Delivering staff awareness training where appropriate

6. Due diligence

Kairox Recruitment Limited seeks to minimise the risk of modern slavery by:

• Verifying worker identity and Right to Work
• Carrying out appropriate compliance checks before placements
• Maintaining accurate recruitment records
• Working with reputable clients and suppliers
• Monitoring recruitment practices for signs of exploitation

Where concerns arise, appropriate investigations will be carried out and, where necessary, relationships may be suspended or terminated.

7. Reporting concerns

Any employee, worker or business partner who suspects modern slavery, forced labour or human trafficking must report their concerns immediately using the contact details below.

Report to Kairox Recruitment Limited: Telephone 01934 914900. Email info@kairoxrecruitment.co.uk. Website www.kairoxrecruitment.co.uk. Data Protection Contact: Stefan Ghica, Recruitment Director/Co-founder, dataprotection@kairoxrecruitment.co.uk.

Reports will be treated seriously, investigated promptly and handled confidentially wherever reasonably possible.

No individual who raises a genuine concern in good faith will suffer any detriment as a result of doing so.

Reporting externally. If you do not feel able to report a concern to us directly, or you would prefer to speak to an independent organisation, you can also contact:

• Modern Slavery Helpline: 08000 121 700 (24/7, free and confidential)
• Unseen UK: www.unseenuk.org
• Gangmasters and Labour Abuse Authority (GLAA): 0800 432 0804

8. Training

Kairox Recruitment Limited is committed to ensuring employees understand:

• What modern slavery is
• Common warning signs
• Their reporting responsibilities
• Ethical recruitment practices

Training forms part of staff induction and may be refreshed periodically where appropriate.

9. Breaches of this policy

Any employee who breaches this policy may be subject to disciplinary action, which could include dismissal where appropriate.

Kairox Recruitment Limited reserves the right to terminate business relationships with clients, suppliers, contractors or recruitment partners who fail to meet acceptable ethical standards or who are found to be involved in modern slavery or human trafficking.

10. Review

This policy will be reviewed at least annually, or sooner where required by changes in legislation, regulatory guidance or business operations.

Document owner: Recruitment Director. Approved by the Company Director. Next review: 8 July 2027.