Modern Slavery & Human Trafficking Policy

Kelson will not knowingly participate in, facilitate, or benefit from:

• forced or compulsory labour;
• human trafficking or the recruitment of people through coercion, deception, or abuse of vulnerability;
• bonded or debt-based labour;
• child labour;
• withholding wages or using wages, debt, or financial penalties to prevent a person from leaving employment;
• confiscation of passports, identity documents, or other personal documents;
• threats, violence, intimidation, harassment, or other forms of coercion;
• recruitment practices that require workers or candidates to pay fees or costs in order to obtain employment.

People must be free to accept or decline an opportunity, understand the material terms of their employment, and leave employment in accordance with applicable law and contractual terms.

As a search firm, our recruitment practices carry particular responsibility.

We do not charge candidates a fee for being considered for, introduced to, or placed in a role on behalf of a client.

We seek to communicate opportunities accurately and transparently. We do not knowingly misrepresent the nature of a role, the identity of a client, material employment conditions, or the purpose of an approach.

We respect a candidate's decision not to participate in a search and will not use pressure, intimidation, or misleading information to obtain consent.

Where we identify information suggesting that a recruitment process may involve exploitation or coercion, we will pause our involvement and assess the appropriate course of action.

We expect organisations working with Kelson to respect fundamental human rights and applicable labour standards.

Where appropriate to the nature and risk of a relationship, we may conduct reasonable due diligence on clients, suppliers, contractors, or other business partners.

We may decline to work with, or discontinue a relationship with, an organisation where we have credible concerns that modern slavery, human trafficking, or serious labour exploitation is taking place and the concern cannot be adequately addressed.

Modern slavery risks can vary by country, industry, occupation, recruitment model, and the circumstances of individual workers.

We therefore take a risk-based approach rather than assuming that risk is absent.

Particular attention may be given to situations involving:

• vulnerable or migrant workers;
• recruitment through intermediaries;
• complex or opaque labour supply chains;
• high-risk industries or locations;
• significant recruitment or placement fees;
• restrictions on freedom of movement;
• unusual deductions, debt arrangements, or employment conditions;
• indicators of coercion, deception, or intimidation.

Where concerns arise, we will seek to understand the facts, assess the risk, and take proportionate action.

Anyone working with Kelson — including candidates, employees, clients, suppliers, and other stakeholders — may raise a concern about suspected modern slavery or human trafficking.

Concerns should be reported to:

contact@kelsonsearch.com

We will treat concerns seriously and handle them with appropriate confidentiality.

No person who raises a genuine concern in good faith should be subject to retaliation or disadvantage as a result.

Where appropriate and lawful, we may refer suspected criminal conduct to the relevant authorities.

Our objective is not simply to identify a problem, but to help ensure that exploitation is stopped and affected individuals are protected.

Where modern slavery or serious exploitation is identified in connection with our business or relationships, we will consider appropriate remedial action based on the circumstances, which may include stopping or suspending the relevant activity or relationship, supporting access to appropriate assistance, and cooperating with relevant authorities or other appropriate organisations.

We will seek to avoid actions that could unintentionally place affected workers at greater risk.

We aim to ensure that people working for Kelson understand the basic indicators and risks of modern slavery and know how to raise concerns.

We will review this policy and our related practices periodically and update them where appropriate.

Human rights are not a commercial trade-off.

We will not accept a candidate, client relationship, placement, or commercial opportunity at the cost of a person's freedom, dignity, or basic rights.

Kelson's commitment is simple: no forced labour, no human trafficking, and no exploitation.