Modern Slavery Statement

Financial year ending: 31st December 2023

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

KBS Maritime has a zero-tolerance approach to modern slavery and human trafficking and is committed to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place within the Company’s business or its supply chains.

MODERN SLAVERY TRANSPARENCY STATEMENT

In accordance with Section 54 of the Modern Slavery Act 2015, the following statement sets out the steps that KBS Maritime has taken during the year to ensure that there is no modern slavery or human trafficking taking place in our business or supply chains.

Our business and suppliers

KBS Maritime currently has a single contract to provide Hard Facilities Management and alongside services under the FMSP contract with the UK’s Ministry of Defence (MoD) at HMNB Portsmouth. Our business is therefore predominantly comprised of the procurement of engineering specialist advice and materials in support of infrastructure projects followed by the ongoing procurement of spares, maintenance and the provision of services to meet the requirements of a safe operating base.

Our values & policies

KBS Maritime is committed to conducting its business ethically, with integrity, transparency, and in accordance with all applicable laws. The Company recognises that modern slavery is a crime and a violation of fundamental human rights which takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking. As such, KBS Maritime has a zero-tolerance approach to all forms of modern slavery and is committed to implementing and enforcing effective systems and controls to safeguard against any form of modern slavery taking place within its business or its supply chain.

KBS Maritime views the risks of modern-slavery and human trafficking in its business and supply chain to be low. Nevertheless, KBS Maritime has developed its policies and procedures, for example, Code of Conduct and Anti-Bribery policies to ensure that any occurrences of modern slavery or human trafficking are identified and remediated.

All of our employees shall:

  • Have an awareness of the KBS Maritime Code of Business Conduct and have completed the KBS Maritime Code of Conduct Training.
  • Ensure that KBS Maritime only works with organisations who pass our Modern Slavery preselection and due diligence process, have signed up to the KBS Modern Slavery Policy and who have uploaded their modern slavery statements and policies to our supply chain system.
  • Have an awareness, via the available training material, what modern slavery is and have made themselves aware of the potential forms of modern slavery and how to identify where it might be occurring within our supply chain.
  • Immediately report any suspicions of Modern Slavery in our business or supply chains to our Anti-Slavery Officer (KBS Maritime Head of Human Resources).

Steps taken during the year

  • KBS Maritime Code of Conduct specifically references modern slavery and human trafficking. This is included in the training for new starters to our business and provided as mandated annual training for all of our workforce.
  • Our procurement processes have been implemented so that the Company’s zero tolerance approach to modern slavery is communicated at the outset of every new business relationship as part of on boarding via our supplier prequalification and compliance portal.
  • KBS Maritime’s pre-qualification questionnaire (PQQ) includes the requirement for due diligence on a new Supplier’s anti-slavery policies.
  • KBS Maritime has an independent ethics helpline service which can be used by employees to confidentially report any evidence or suspicion of a breach of anti-slavery regulations either within the Company or by its suppliers.

Next steps

  • KBS Maritime will conduct an annual analysis of our suppliers to ensure that we are not trading with organisations that would be deemed as being high-risk organisations with regards to modern slavery.
  • All Employees’ mandated to complete annual Code of Conduct training, with the objective of embedding respect for human rights and zero tolerance of modern slavery throughout the organisation.

KBS Maritime recognises the continuously changing nature of modern slavery, and therefore the company will continue to review the level of modern slavery risk in its business and supply chain, and to adapt policies and procedures so they remain proportionate to the identified risk and the size and operations of the Company.

This statement has been approved by the KBS Maritime Board of Directors and satisfies the requirements of the UK ‘Modern Slavery Act 2015’

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