Anti-slavery & Anti-trafficking Policy

Anti-slavery and Anti-trafficking Policy

Purpose

Modern slavery encompasses slavery, forced and compulsory labour, and human trafficking whereby individuals are deprived of their freedom and are exploited for commercial or personal gain as defined in the Modern Slavery Act 2015. The Key Group is committed to combating slavery and human trafficking and to acting with integrity in all its dealings, relationships, and supply chains. It expects the same high standards from all its employees, suppliers, contractors, and those with whom it does business. 


Who is this policy for?

This policy applies to all employees, workers, consultants, and other persons doing business with The Key Group, including all its wholly owned companies, contractors, and suppliers. 


Responsibilities

The People Team have the responsibility for: 

  • Updating this policy and keeping it up to date 

  • Providing appropriate training about modern slavery

Employees are responsible for:

  • Reading and keeping up-to-date with this policy, and adhering to its contents

Policy

The Key Group acknowledges the risk that a supply chain may involve the use of a hidden or unknown subcontractor reliant on forced labour. Although The Key Group as a technology and content provider considers the risk of modern slavery to be low due to the nature of its supply chains, it takes its responsibilities to combat modern slavery seriously as demonstrated by its promotion and adoption of the following policy measures:

  • The prevention, detection, and reporting of modern slavery in any part of its business or supply chains is the responsibility of all those working for The Key Group or under its control.

  • Appropriate due diligence processes must be carried out in relation to modern slavery which may include considering human rights in a sector or country, the type of sector in which a service provider operates, the countries from which services are provided, the nature of relationships with suppliers, and the complexity of supply chain(s).

  • All supply chain lines need to be periodically risk assessed and managed in relation to modern slavery and checks conducted on high-risk suppliers. The Key Group’s standard procurement and contract procedures and documentation address anti-slavery and anti-trafficking. 

  • The Key Group has developed an online training module on anti-slavery and anti-trafficking and completion is required or encouraged for a range of relevant new and existing employees, including all Finance Division staff and those in financial or purchasing roles across the wider group.

  • The Key Group encourages anyone to raise any concerns about modern slavery, using its whistleblowing policy if necessary, and will support anyone who acts in good faith.

  • The Key Group will continue to develop its commitment to combat modern slavery and human trafficking and will outline such activities within its annual anti-slavery and anti-trafficking statement.

Any breaches of this policy may result in The Key Group taking disciplinary action against individual(s) and/or terminating its relationship with any organisation or supplier.

Last updated 25 February 2026