The Company (Kemosabe) is committed to corporate governance and lawful and ethical behaviour is of paramount importance and critical to its continued success. The Kemosabe Code requires all employees to operate with integrity and transparency in all interactions with clients and other partners and places similar obligations upon its suppliers.


The Company is fully supportive of the laws introduced within the United Kingdom through the Modern Slavery Act 2015 to combat slavery, forced or compulsory labour and the trafficking of persons for any purpose (“Slavery and Human Trafficking”). This statement is made in respect of the Kemosabe’s financial year ending 30 March 2020 and is made in accordance with Section 54 of the Modern Slavery Act and outlines the steps that The Company takes and intends to take to protect its business against all forms of Slavery and Human Trafficking.


Copies of statements made by The Company in respect of previous financial years are made available on request to the Company Secretary.


Business and Structure

The Company suppliers worldwide include, without limitation, production and design companies, IT and communications services, including software and hardware suppliers, office supplies and equipment, couriers, transportation services, such as road transportation, airlines and train companies, merchandise suppliers, and hospitality service suppliers including hotel conference or venue providers, catering suppliers, professional services such as auditors, actuaries, tax advisors, legal advisors, insurers, banks and talent and recruitment agencies.


Relevant Policies

Doing business in an ethical and responsible manner is already enshrined within Kemosabe’s policies and procedures and in particular, those referred to below help to ensure that Slavery and Human Trafficking do not occur within Kemosabe or its supply chains.


Kemosabe requires all its suppliers, employees, agents and subcontractors to adhere to the Kemosabe Supplier Code of Conduct while doing business with or on behalf of Kemosabe. The Kemosabe Supplier Code of Conduct specifically requires use of voluntary labour and prohibits slavery, servitude or the use of forced or compulsory labour and human or labour trafficking and requires all suppliers to comply with applicable laws. The Interpublic Alert Line, allows employees or other concerned parties (including prospective and current suppliers and clients) to raise concerns about any business conduct without fear of reprisal or retribution.

Compliance is supported by a robust Internal Audit function which regularly conducts audits of all areas of our business and works closely with the internal Legal Department to ensure compliance with all applicable laws and regulations.


Risk Assessment

Kemosabe have legal obligations under the Modern Slavery Act 2015.

Kemosabe sources its suppliers in a responsible manner under Global Sourcing and Procurement and Third Party Supplier Due Diligence Guidelines and fully expects and requires its suppliers to operate in full compliance with all applicable laws. A failure by a supplier to comply with applicable laws (including as they relate to Slavery and Human Trafficking) would be a justifiable reason for such relationship to be terminated.

Given the nature of our business, Kemosabe does not consider that there is a significant risk of Slavery and Human Trafficking within its supply chain or its own business and no instances of Slavery and Human Trafficking have been identified by Kemosabe. Kemosabe continues to build upon its robust compliance culture and seeks to maintain its high standards. As part of its ongoing efforts to insure there is no Slavery or Human Trafficking in its supply chain it intends to identify improvements by reviewing its supplier engagement policies, contractual approaches and due diligence processes to continually monitor the risk of Slavery and Human Trafficking.

Rebecca Adair


Faithful Friend. Trusty Scout Limited (trading as Kemosabe)

October 2020