Modern Slavery Act Statement​

Kaizen Policies logo

Effective Date: January 1, 2020.

Kaizen Compliance Solutions Limited (hereinafter referred to as “Kaizen”, “Us”, “Our” or “We”) are a people and values-driven organisation (firm), and we aspire to meet the highest professional, legal, moral and ethical standards and codes that are expected of us from our various clients, people and governments worldwide.

As a participant; through or consultants in several workshops such as the Viadrina G20 Conference in Hamburg in 2017 and symposiums on Compliance & Human Rights, Kaizen supports the protection of internationally proclaimed human rights, the elimination of all forms of forced and compulsory labour and the effective abolition of child labour and we are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business.

We go further and take seriously our commitment to assisting organizations and grass-root initiatives that promote human rights and tackle discrimination, forced-labour and child-labour practices through our corporate social initiatives and by supporting charities such as IBWU, Rotary or UNICEF. We also discourage this ill vice through awareness programmes made by our consultants in employee motivational initiatives within some Financial Institutions, or through Kaizen’s association and partnership with higher institutions such as the City University London Graduate Scheme programmes and our wide range of philanthropic, civic and academic initiatives of this nature; both at local levels (within the United Kingdom) and at a global levels, through diverse pro bono activities and memberships.

This statement below sets out our commitment and approach towards modern slavery:

Our Firm

Our firm; Kaizen Compliance Solutions Limited, is a UK based and registered firm which offers consulting, advisory and training services to several sectors including but not limited to banking, FI’s, Payment Services, Telecoms, Mining & Extractive firms, Life Sciences, Oil & Gas, Legal and Law Enforcement firms/agencies, on AML, AB&C, Sanctions and Compliance related matters.

We help our clients make significant and lasting improvements to their performance and realize their most important goals. Given the nature of the services we provide and the professional workforce we employ, hire, work with (or) partner with, we assess the risk of modern slavery or human trafficking in our own organisation to be low. Our contracts with employees or partnership arrangement also reflect the position of the law.

Our Supply Chain

Our supply chain comprises primarily of 3rd party risk service firms, including local and foreign based professional advisory services, Risk Intelligence tools, IT services, as well as office supplies. We have reviewed our supply chain and believe the overall risk of modern slavery is low owing to the following proven factors:

 

·        The nature of the goods and services which we procure (mostly services, mostly skilled professions).

·        The locations from which we procure them (mostly within the United Kingdom and if international, mainly from within developed markets).

·        The retainership model. We tend to use firms we have historic ties with and know and understand the structure, culture and workforce

·        The level of due diligence we perform is extensive and targeted towards determining our risk exposure prior to engagement

·        Our procurement strategy encourages reasonable terms and ensures timely payment.

While the overall level of risk is low, these criteria also enables us to identify where the risk may be higher.

Our policies on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business. Our internal policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chain or in resources that we employ, contract with or associate with.

Due diligence processes for slavery and human trafficking

Where we hire resources for contract/consulting work through third party recruitment firms, we insist that their hiring procedures and due diligence checks are reflective of our stand against slavery and human trafficking. In instances where we deal directly with resource allocation, supply chain or work with end clients, we conduct routine due diligence checks and raise awareness of these issues with colleagues who manage our internal vetting process. The due diligence process reflects the relative risk for potential resource and 3rd party supply chain entities & individuals and includes:

 

• Checks against global sanctions and enforcement databases (for example, OFAC, World Bank Debarment List; which can be found at this link) and subject to adverse media review to identify risks including human rights abuses, human trafficking and labour violations.

 

• Plans to embed in our risk assessment an evaluation of modern slavery based on criteria such as the country of operation and government response, as assessed by the Global Slavery Index which can be found at this link

 

• Those potential human resource and supply chain entities that are identified as medium or high risk are subject to further vetting and evaluation based on the specific circumstances.

Workplace Discrimination and Diversity Statement

We are committed to building a firm which promotes and /or reflects the diversity of the United Kingdom and in line with best practices whilst valuing the experiences  which the diverse background of our employees/contractors/consultants would bring. Our employment policies and practices are constantly being reviewed  to prevent any bias based on the race, sex, ethnicity, disability, marital / civil unions and age, of our diverse employees in the firm, and expect that our suppliers, partners and clients apply same policies to enhance their workplace diversity.

Ongoing steps

We at Kaizen Compliance Solutions Limited do not tolerate work place discrimination, slavery, forced labour or human trafficking in any form whatsoever and expect our partners, suppliers and clients to adhere to the same standards.  Since our last published slavery and human trafficking statement dated January 2019, we have not had any incident of abuse of the process and we insert clauses in our contracts involving partnership agreements where we work with labour force/resources to fully comply with the applicable legal requirements of slavery, forced labour and human trafficking laws (including the UK Modern Slavery Act 2015) and we expect our partners and suppliers to enact practices to ensure compliance with such laws. We remain committed to continually improving our practices to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

 

This statement is made pursuant to section 54(1) of the United Kingdom Modern Slavery Act 2015 and articles 1 & 4 of the United Nations Declaration of Human Rights of 1948 and both  principles within constitute the framework to our work place discrimination, slavery and human trafficking statement for the financial year ending 31 December 2020. 

Tom Brown
CEO (Chief Executive Officer)
Kaizen Compliance Solutions Limited
United Kingdom,
January 2020

Neil Marshall MICA
COO (Chief Operating Officer)
Kaizen Compliance Solutions Limited
United Kingdom,
January 2020