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Modern slavery is a criminal offence under the Modern Slavery Act UK 2015 (the “Act”). The Act imposes obligations on organisations of a certain size which carry on a business in the United Kingdom. “Modern slavery” refers to the offences of human trafficking, slavery, servitude, and forced or compulsory labour. 

KTL has a zero-tolerance approach to modern slavery. 

We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. 

We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains and we expect the same high standards from all of our contractors, suppliers and other business partners. 

In summary: 

  • We have a zero-tolerance attitude to modern slavery. 

  • We are committed to opposing modern slavery in all its forms and preventing it by whatever means we can. 

  • We demand the same attitude of all who work for us and expect it of all with whom we have business dealings. 

 

In order to prevent the occurrence of incidents of modern slavery within our own business and throughout our supply chain we shall: 

  • Identify, monitor and assess those areas of our business and supply chain most at risk from modern slavery and implement initiatives to enhance risk management effectiveness. 

  • Engage with our contractors, suppliers and other business partners at the outset of our business relationship to convey to them this policy and to require them to comply with it, and with the principles enshrined in the Act, at all times. 

  • Incorporate anti-slavery and human trafficking obligations as part of our procurement agreements and contractual processes and, where appropriate, carry out an audit and/or investigation of the activities of those contractors, suppliers or business partners deemed high risk; and 

  • Provide training to relevant employees to facilitate achievement of the objectives of this policy. 

 

2025 Financial Year 

We confirm we implemented the above steps during the financial year ended 31 December 2026 to ensure that slavery and human trafficking is not taking place. 

MODERN SLAVERY
POLICY STATEMENT

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Signed 

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Alan Hanamy 
Chief Executive Officer 

31 March 2026

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