Modern Slavery Act Statement

KafKai™ Ltd (“the Company”) is committed to continually improving its practices to combat slavery and human trafficking.  KafKai™ has zero tolerance of modern slavery, in all its different forms, both in its operations and in its supply chains.

KaifKai’s modern slavery statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the ‘Act’). It constitutes the Company’s anti-slavery and human trafficking statement for the financial year ending 31 December 2024. KafKai™ aims to be transparent about its approach to modern slavery, and this statement outlines its approach to prevent modern slavery and human trafficking in its operations and its supply chains.

KafKai™ is not aware of any slavery or human trafficking in any part of our operations or supply chain, and no issues were raised during the year ended 31 December 2024. Therefore, and taking into account the nature of KafKai’s business, we consider that there is limited risk of modern slavery compared to other businesses. However, we recognise our responsibility in managing our business and supply chains responsibly to mitigate and where necessary, remediate the risks of modern slavery.

Introduction

The term modern slavery is a broad one. It considers someone to be in modern slavery if they are in forced labour, servitude, slavery, human trafficking, debt bondage, forced or servile marriage, descent-based slavery or child exploitation. It is a global and growing issue. No sector or industry is exempt from the potential for modern slavery. KafKai™ has zero tolerance for modern slavery in all its forms. It has a responsibility to understand the risks in its business and supply chain and manage those risks accordingly.

Our commitment to the principles of the Modern Slavery Act 2015

KafKai™ remains committed to managing and mitigating the risk of modern slavery or human trafficking taking place anywhere in the business, or in any of its supply chains.  In 2025, we will continue to ensure that there is good awareness amongst our employees of the areas of high risk and an understanding of the potential issues of modern slavery across the business.

As a software and IT company, KafKai™ does not use an extensive range of local or international suppliers where modern slavery or human trafficking would generally be a material risk. The Company is committed to acting ethically and with integrity in all of its business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking does not take place anywhere in the business or supply chains. Due to the nature of the Company, we have identified that the overall risk to the facilitation of modern slavery was low, due to its limited supply chain.

Our policies and Governance

Our commitments are reflected in KafKai’s company-wide policies, which set the standard of expected business behaviour for all employees. Relevant policies include:

  • Suppliers Code of Conduct, which promotes ethical business practices and requires suppliers to conduct business in accordance with applicate laws and regulations.
  • Ethics and Code of Conduct Policy, which details the policies in relation to ethics, anti-corruption and bribery. 
  • Our staff handbook, which aims to foster a workplace environment that is fair, open and respectful, and one that promotes and protects the rights and dignity of all employees.
  • Whistleblowing Policy encourages employees to speak up and report any potential signs of wrongdoing or concerns about illegal activity.
  • Harassment Policy to ensure our employees have a safe place of work, free from any form of bullying or harassment.
  • Equality, Diversity, and Inclusion Policy, ensures that we foster a fair and inclusive workplace, where our people are valued, their differences are respected, and discrimination is eliminated.
  • Recruitment processes, provides equality and fairness for all those who apply to us for employment and all those in our employment and not to discriminate in any circumstance.

KafKai™ reviews its procurement processes and associated policies to ensure that there is an appropriate approach taken to managing modern slavery in its supply chain and to set out its expectations of its supply chain partners. 

Effectiveness in combating slavery and human trafficking 

KafKai™ understands that it has a responsibility to continue to assess and mitigate the risk of modern slavery in its supply chain in the long term. While the Company continues to make progress in this area, future developments will be to update understanding and reassess the nature of that risk, assessing whether policies and controls are appropriate and also to ensuring that controls to manage any risk are operating effectively if that risk arises. It is expected that the nature of the risk may change over time and ongoing vigilance will be required.

Due diligence processes for slavery and human trafficking

KafKai™ remains committed to running its business responsibly and, in order to maintain visibility across its supply chains. KafKai™ has in place a Supplier Code of Conduct and Procurement Policy to address, among other things, issues of child labour, compulsory labour and human trafficking. All new suppliers with anticipated spend exceeding £25,000 (or local current equivalent), are required to confirm that they have in place or adhere to modern slavery legislation. All new suppliers, subject to an annual spend threshold, must go through the KafKai™ Supplier onboarding process and are required to sign up to the KafKai™ Supplier Code of Conduct or confirm they have equivalent policies in place, providing reassurance that they understand the importance we place on these issues right from the start of our relationship with them.

Where not already addressed, adherence to the Code is included in commercial agreements, either when KafKai™  enters into contracts with new suppliers and/or when contracts with existing suppliers are renewed. KafKai™ is committed to only working with suppliers who take their obligations towards modern slavery as seriously as we do and who will adhere to the tenets of our Supplier Code of Conduct.

KafKai™ recognises the importance of knowledge and our role in mitigating the risk of slavery and human trafficking.

To assess the effectiveness of controls to ensure modern slavery does not exist within any of the business activities, KafKai™ aims to, in 2025:

  • Continue to review the effectiveness of the Supplier Code of Conduct, and Supplier On-Boarding process;
  • Continue to strengthen due diligence processes in relation to our vendor relationships;
  • Continue to ensure awareness of the signs of modern slavery and human trafficking and the reporting mechanisms if a case of slavery or human trafficking is suspected; and
  • Monitor government and other perspectives and approaches to modern slavery and actively consider their applicability to the Company.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Company’s slavery and human trafficking statement for the financial year ending 31 December 2024. The statement was approved by the Board of KafKai Ltd on 31 March 2025.

Signed by K Khurshid, Director on behalf of KafKai Ltd