Modern Day Slavery Policy

Introduction

Slavery, servitude, forced labour, and human trafficking (Modern Slavery) are global and growing issues. These have come to prominence given the rapid rise in global migration that exists in every region in the world and in all economies, whether industrialised or developing. They impact all sectors and industries. KMS Lighthouse has a zero-tolerance approach to Modern Slavery within our own operations and our supply chains. All stakeholders in our business and supply chain have a responsibility to be alert to these risks, however small. Whenever our staff have any concerns about issues at work, they are encouraged to speak to their human resources business partner.

Our Business and Supply Chains

KMS Lighthouse is a knowledge management solution provider developing its advanced knowledge management platforms to enhance customer experience and operational efficiency. As of the date of this statement, KMS Lighthouse operates in multiple countries including the US, UK, Australia, Italy, Israel, Portugal, Serbia and Singapore. The principal first-tier suppliers of our group companies comprise mostly software providers. While we currently source the majority of our products directly from countries that are not deemed at high risk of Modern Slavery, we recognize that there is a wider risk of modern slavery in the lower tiers of our supply chain and from our smaller suppliers.

Policies

KMS Lighthouse’s internal policies regarding employee behaviour are set out in our Code of Conduct. This covers related human rights areas such as discrimination and harassment. Specifically, we state that KMS Lighthouse does not permit or tolerate any form of discrimination and/or harassment based on an individual’s age, race, religious creed, colour, national origin, ancestry, mental or physical disability, medical condition, genetic information, marital status and partnership status, sex (including pregnancy, childbirth, breastfeeding and/or related medical conditions), gender, gender identity, gender expression, sexual orientation, military or veteran status, national origin (including language use restrictions) or any other status protected by federal, state, or local laws. All forms of harassment and/or discrimination of, or by, employees, applicants, unpaid interns, volunteers, vendors, visitors, customers, and clients are strictly prohibited and will not be tolerated.

Our recruitment policy requires that KMS Lighthouse only uses reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

Our Whistleblowing Policy, aimed at our employees, encourages team members to report any wrongdoing which they believe is ‘in the public interest’. We hope that if any of our team were to identify any cases or suspicions of Modern Slavery, that these would be reported pursuant to our Whistleblowing Policy. All reports are fully investigated and appropriate remedial actions taken.

Due Diligence and Risks

Before a supplier can enter into a contractual relationship with KMS Lighthouse, they need to undergo a take-on assessment. This results in identification and assessment of potential risk areas in KMS Lighthouse’s business and supply chains and lead to us introducing appropriate mitigating procedures, including monitoring, to minimise the likelihood of modern slavery and human trafficking arising.

Modern Slavery Training

Within KMS Lighthouse, we endeavour to provide sufficient training to enable our team to undertake their roles to the best of their abilities. Since the recognition by various countries that Modern Slavery is a risk within business, we are looking to develop training and capacity building for our team.

Prevention of Modern Slavery in Our Supply Chain

Our team is committed to taking forward our commitment to eradicate modern slavery in our supply chains. To do this we have embarked on the following programme:

  • Introduced a risk-based approach to identify and assess potential risk areas in KMS Lighthouse’s business and supply chains.
  • Introduced a Modern Slavery clause within our supplier contracts, including the right to audit.
  • Prepared a supplier code of conduct which sets out our expectations of suppliers if they wish to work with KMS Lighthouse.

We are committed to improving our understanding and management of modern slavery risks over time. We expect our approach to managing the risk of modern slavery to continue to evolve as we learn from the actions that we have set out above.

Last reviewed: December, 2024.

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