Modern Slavery Statement

Introduction

Kumi Consulting Ltd. (Kumi) is a sustainability consultancy solely committed to responsible sourcing. Our purpose is to build responsible supply chains through providing management consultancy to companies, industry initiatives, civil society and governments and policy makers.

Our commitment to sustainable business practices means that we endeavour to operate ethically and transparently. While Kumi is not subject to the UK Modern Slavery Act 2015, we believe it is important to play our part in the fight against modern slavery and to publish our commitment and procedure. This document outlines our commitment to eradicating modern slavery and our due diligence procedure for our suppliers.

Our Commitment

Conducting our business in a responsible manner is of the utmost importance to us. Kumi has zero tolerance regarding modern slavery and human trafficking. This includes employees, associates, contractors (including sub-contractors) and partners.

We define modern slavery according to the UK Government’s definition:

Modern slavery is defined as the recruitment, movement, harbouring or receiving of children, women or men through the use of force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation. It is a crime under the Modern Slavery Act 2015 and includes holding a person in a position of slavery, servitude forced or compulsory labour, or facilitating their travel with the intention of exploiting them soon after.

Given the nature of our work as a professional services company, we consider the risk of modern slavery in Kumi’s supply chain to be low. Nevertheless, we commit to establishing and maintaining a due diligence procedure that identifies modern slavery and other adverse social risks.

Our Approach

Team

Kumi’s employees are based in the UK and Germany. Our onboarding and supplier due diligence process is undertaken in our London offices. Our Operations Director is responsible for onboarding new suppliers. This role includes overseeing Kumi’s ESG Committee, undertaking due diligence on new suppliers and reporting on these matters to the Managing Director.

Assessing and identifying risks

1. Tracking suppliers: We record the key information of all of our suppliers in a database, such as key contact information, the country location of the supplier, the type of company the supplier is.

2. Assessing inherent risk: We determine if suppliers are operating in high-risk countries or in high-risk industries using a range of publicly available indicators that cover topics such as human rights, labour rights, conflict and governance risks.

3. Enhanced due diligence: In cases where we source services from a high-risk country or industry, we undertake enhanced due diligence. This involves requesting suppliers to complete an ESG questionnaire, which is relevant to the suppliers’ circumstances. Alternatively, if red flags are raised about suppliers who are not in high-risk countries or industries, we will also undertake enhanced due diligence.

Risk management and mitigation

If risks or impacts are identified, we will communicate with the supplier to discuss appropriate actions and next steps, appropriate to the circumstance identified.

To date, Kumi has not identified any adverse impacts in its supply chain.

Reviewing effectiveness

The ESG Committee reviews Kumi’s due diligence process and this process annually, at the end of the financial year.