Introduction
The crime of modern slavery is a vile and morally condemnable act that deprives individuals of their freedom and dignity for the benefit of others. It is a significant issue affecting millions of people worldwide, including those in developed nations, who are subjected to various forms of slavery and exploitation. Every company faces the risk of being complicit in this crime, both within its own operations and across its supply chain.
At Kynd Medical (‘Kynd’), we maintain a steadfast zero-tolerance stance against modern slavery. We are fully dedicated to preventing slavery and human trafficking in all aspects of our business and supply chain. We have taken concrete measures to combat modern slavery, as detailed in our statement. Although not legally obligated to publish a modern slavery statement, we have chosen to make it available on our organisation’s website.
This statement outlines the actions we have undertaken to identify potential modern slavery risks associated with our operations and implement preventive measures during the financial year 2023 and beyond.
Our Business and Supply Chains
At Kynd our objective is to produce top-quality CBD products that contribute to enhancing people’s lives. While our supply chain and customer base are in the United Kingdom, United States, European Union, and Asia we achieve this objective by upholding the highest standards of integrity, ingredients, and manufacturing processes. We meticulously trace the origin of all our product ingredients, including batches, suppliers, and internal inputs, ensuring complete traceability from seed to belly.
We cultivate relationships with our suppliers based on trust and integrity, grounded in mutual benefits. Our supplier selection and onboarding procedures encompass thorough due diligence, including assessing suppliers’ reputation, adherence to legal requirements, compliance with health, safety, and environmental standards, and reference checks.
To date, we have not received any allegations of human trafficking or slavery activities involving our suppliers. However, if such allegations were brought to our attention, we would promptly act against the implicated supplier and report the matter to the appropriate authorities.
Risk Assessment
During the past year, we conducted a comprehensive risk assessment of our supply chain, considering factors such as:
- The risk profile of individual countries as determined by the Global Slavery Index.
- The nature of services provided by our suppliers.
- The presence of vulnerable demographic groups.
- An analysis of news reports and insights from labour and human rights organisations.
Based on this assessment, we determine our response and establish risk controls to be implemented.
Policies
At Kynd we have implemented the following policies to identify and prevent slavery and human trafficking in our operations:
- Whistleblowing Policy: We actively encourage all employees, customers, and suppliers to report any suspicions of slavery or human trafficking without fear of reprisal. We provide a confidential helpline to safeguard the identity of whistle-blowers.
- Code of Conduct: Our code explicitly outlines the expected actions and behaviours for employees representing our business, promoting the highest standards of employee conduct and ethical behaviour both domestically and throughout our supply chain.
- Purchasing Code: We have updated our Purchasing Code and supplier contracts to explicitly address issues of slavery and human trafficking.
Supplier Due Diligence
Kynd conducts rigorous due diligence on all new suppliers during the onboarding process and periodically reviews existing suppliers. This includes:
- Assessing risks associated with specific services provided.
- Conducting audits to evaluate suppliers’ adherence to health and safety standards, labour relations, and employee contracts.
- Requiring remedial actions to address substandard employment practices.
- Imposing sanctions on suppliers failing to improve their performance in alignment with our requirements.
We expect all suppliers to confirm the following:
- They refrain from utilising any form of coerced, obligatory, or enslaved labour.
- Their employees work voluntarily and possess the right to terminate their employment.
- Each employee is provided with an employment contract that includes a reasonable notice period for ending their employment.
- They do not require employees to submit a deposit or bond, nor do they withhold salaries for any reason.
- They do not demand employees to surrender their passports or work permits as a condition of employment.
Awareness
Kynd has heightened awareness regarding the issue of modern slavery by displaying posters throughout our facilities and sending a dedicated email to all staff members. The email elaborates on:
- Our unwavering commitment to combat modern slavery.
- Indicators that may signify potential cases of slavery or human trafficking.
- Guidelines for employees to report suspicions of modern slavery.
Training
In addition to the awareness program, Kynd has introduced a fresh e-learning course for all employees and supplier contacts, covering:
- Different manifestations of modern slavery involving the coercion and exploitation of individuals.
- The magnitude of the problem and the risks it poses to our organisation.
- Ways for employees to identify signs of slavery and human trafficking, including unreasonably low prices.
- How employees should respond if they suspect instances of slavery or human trafficking.
- Steps for suppliers to escalate concerns related to slavery or human trafficking within their own organisation.
- Available external assistance for victims of slavery.
- Guidelines and instructions to be provided to suppliers regarding slavery policies and controls.
- Actions that Kynd will take if a supplier fails to implement anti-slavery policies or controls.
- An affirmation from employees indicating their compliance with Kynd’s anti-slavery policy.
Performance Measurement
Kynd has established a set of key performance indicators and controls to address modern slavery and human trafficking in our organisation and supply chain. These include:
- The number of employees who have completed mandatory training.
- The number of suppliers who have completed our ethics questionnaire.
- The number of suppliers who have implemented an awareness and training program equivalent to ours.
- The number of reports filed by employees demonstrating their awareness of and sensitivity to ethical issues.
- The findings of our cross-functional Human Rights team, which evaluates our efforts in combating modern slavery and human trafficking.
This statement applies to the period from 31 August 2022 to 01 September 2023 and has been approved by the owners of Kynd.