Governance & Ethics Policies and Procedures
Kestronics Limited (Registered in England and Wales, Registered No. 02337714) are committed to ensuring that our operations and supply chains are free from slavery and human trafficking. This statement summarises our legal and ethical obligations and policies. We recognize our responsibility to uphold ethical business practices and promote transparency in our workforce and partnerships.
Kestronics Managing Director is responsible for the implementation, execution and adherence to this statement.
Our Business
Kestronics is a technology provider of technology solutions and services for end-to-end supply chain management. Working closely with many well-known industry brands offering products such as mobile computers and tablets, barcode scanners, thermal printers, RFID readers, POS systems. With a commitment to integrity and excellence, we strive to foster a work environment that respects human rights and adheres to high ethical standards.
Legal Policy
Kestronics adheres to all local and national laws, ensuring compliance in every aspect of our business operations and partnerships.
Employee Code of Conduct
Purpose
This Code of Conduct sets out the expected behaviour of all employees at Kestronics.
Key Principles
1. Integrity: Employees must act with integrity, honesty, and professionalism in all business dealings.
2. Respect: Employees must treat colleagues, suppliers, and customers with respect and dignity, promoting an inclusive workplace.
3. Compliance: Employees are expected to comply with all relevant laws, regulations, and company policies.
Recruitment Policy
Purpose
This policy outlines Kestronics’ approach to recruitment, ensuring fair and transparent practices.
Key Principles
- Fairness and Transparency: Recruitment processes must be fair, transparent, and free from discrimination.
- Qualifications: Candidates must be assessed based on their skills, qualifications, and experience relevant to the role.
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No Exploitation: Kestronics will not engage in practices that exploit or take advantage of candidates, including the charging of fees to workers for employment.
Supplier Code of Conduct
Purpose
To establish clear expectations regarding ethical conduct, compliance with laws, and respect for human rights among all suppliers and their employees.
Scope
This Code applies to all suppliers and their subcontractors involved in the supply of goods and services to Kestronics.
Key Principles
1. Compliance with Laws: Suppliers must comply with all applicable laws and regulations in the countries in which they operate.
2. Human Rights and Labour Standards: Suppliers must ensure their operations do not violate human rights and must adhere to international standards of labour, providing safe working conditions, fair wages, and reasonable working hours.
3. Freedom of Movement and Employment: Suppliers must ensure that all workers are free to terminate their employment at any time and must not restrict the movement of workers by confiscating identification documents or passports.
4. Prohibition of Forced Labour: Suppliers must not engage in forced, bonded, or indentured labour.
5. Prohibition of Child Labour: Suppliers must not employ individuals below the minimum legal working age.
6. Freedom of Association: Suppliers must respect the right of workers to freely associate, organise, and bargain collectively, without fear of retaliation or harassment.
7. Zero Tolerance for Violence, Harassment, and Intimidation: Suppliers must ensure a work environment free from threats of violence, harassment, or intimidation.
8. Prohibition of Compulsory Overtime: Suppliers must ensure that overtime is voluntary and not imposed under coercion.
All policies are made available to workers within our supply chain, either directly through suppliers or via their representatives. Suppliers are required to ensure these policies are accessible and understood by their workers.
Enforcement
Kestronics reserves the right to audit suppliers to ensure compliance with this Code. Non-compliance may result in the termination of the business relationship.
Procurement Policy
Purpose
The purpose of this policy is to ensure ethical procurement practices that promote sustainability and human rights.
Key Principles
1. Supplier Evaluation: Kestronics will evaluate suppliers based on their ethical standards and commitment to human rights.
2. Sustainability: The procurement process must consider environmental and social impacts, promoting sustainable practices in our supply chain.
3. Transparency: Kestronics will maintain transparency in procurement processes, ensuring all stakeholders understand the decision-making criteria.
High-Risk Supplier Policy
Purpose
To mitigate risks within our supply chain by ensuring that high-risk suppliers adhere to our ethical standards.
Key Principles
1. Supplier Audits: High-risk suppliers must undergo regular audits to ensure compliance with Kestronics’ ethical standards.
2. Contractual Obligations: High-risk suppliers must adhere to our policies as a condition of their contracts.
3. Supplier Training: We provide relevant training to high-risk suppliers to ensure they understand and comply with our ethical standards, including the prevention of modern slavery.
Migrant Worker Policy
Purpose
This policy outlines Kestronics’ commitment to the fair treatment of migrant workers and the prevention of exploitation.
Key Principles
1. Fair Recruitment: Kestronics will ensure that all migrant workers are recruited through fair and transparent processes, free from coercion and deception.
2. No Recruitment Fees: Migrant workers must not be charged recruitment fees or forced into debt as a condition of employment.
3. No Confiscation of IDs: Suppliers and employers are prohibited from withholding migrant workers’ identification documents.
4. Respect for Rights: All migrant workers must be treated with respect and dignity, receiving fair wages and working conditions in accordance with local laws.
5. Freedom of Movement: Migrant workers must not be subjected to restrictions on their freedom of movement outside working hours.
6. Access to Information: Migrant workers must be provided with clear and accurate information about their employment terms and conditions before accepting a job.
Child Labour Policy
Purpose
Kestronics is committed to preventing child labour in all its operations and supply chains.
Key Principles
1. Prohibition of Child Labour: Kestronics will employ workers under the age of 15, and will not tolerate the use of child labour in any form, and all suppliers must adhere to this policy.
2. Age Verification: Suppliers must implement robust age verification processes to ensure no one below the legal working age is employed.
3. Support for Education: Kestronics encourages suppliers to support the education of children in their communities, ensuring they have access to schooling and development opportunities.
Purpose
This policy expresses Kestronics’ commitment to upholding human rights in all aspects of our operations.
Key Principles
1. Respect for Human Rights: Kestronics is committed to respecting and promoting human rights in accordance with the Universal Declaration of Human Rights.
2. Non-Discrimination: Kestronics prohibits discrimination on any grounds, including but not limited to race, gender, age, religion, or disability.
3. Reporting Mechanism: Kestronics provides accessible channels for employees and stakeholders to report human rights violations or concerns without fear of retaliation.
4. Freedom of Association: Workers must be free to join trade unions and engage in collective bargaining.
5. Access to Remedy and Compensation: Victims of modern slavery within our operations or supply chains must have access to remedies, compensation, and justice.
6. Zero Tolerance for Violence and Harassment: We prohibit any form of violence, harassment, or intimidation in our workplace and supply chain.
Prohibition of Corruption and Bribery
Purpose
Kestronics is committed to conducting its business with integrity and transparency. This policy outlines our strict prohibition of corruption and bribery in all forms.
Key Principles
1. Zero Tolerance: Kestronics has a zero-tolerance approach to corruption and bribery. Employees, suppliers, and partners must not offer, give, request, or accept bribes or other improper payments in any form.
2. Gifts and Hospitality: Any gifts or hospitality given or received must be modest, appropriate, and compliant with applicable laws and regulations. Employees must seek prior approval for any gifts or hospitality that may exceed reasonable limits.
3. Compliance with Laws: All employees and suppliers are expected to comply with anti-corruption and anti-bribery laws applicable in their respective jurisdictions.
4. Reporting Mechanism: Employees are encouraged to report any suspected instances of corruption or bribery through the established reporting channels. Kestronics ensures that all reports will be taken seriously and treated confidentially.
5. Training and Awareness: Kestronics will provide training to employees to ensure they understand the risks of corruption and bribery and how to identify and prevent such activities.
Staff Training and Awareness Policy on Modern Slavery
Purpose
This policy aims to enhance awareness of modern slavery and ensure that all employees are equipped to identify and address risks.
Key Principles
1. Training Programme: Kestronics will implement a comprehensive training programme for all employees on modern slavery, its signs, and prevention measures.
2. Awareness Campaigns: Regular awareness campaigns will be conducted to reinforce the importance of vigilance and reporting concerning modern slavery.
3. Ongoing Education: Kestronics is committed to providing ongoing education and resources to employees to ensure they remain informed about modern slavery and related issues.
Equal Opportunities and Diversity Policy
Purpose
Kestronics is committed to promoting equality and diversity in the workplace and ensuring that all employees, suppliers, and customers are treated fairly, without discrimination.
Key Principles
1. Equal Opportunities: Kestronics provides equal opportunities for all individuals, regardless of race, gender, age, disability, sexual orientation, religion, or any other characteristic protected by law.
2. Diversity: We value diversity and strive to create an inclusive environment where different perspectives and experiences are welcomed and respected.
3. Non-Discrimination: Discrimination, harassment, or victimisation of any kind will not be tolerated. Employees are encouraged to report any instances of unfair treatment, which will be investigated promptly and confidentially.
4. Recruitment and Development: Our recruitment, promotion, and development processes are based solely on merit, skills, and performance, ensuring fair treatment for all candidates and employees
Environmental Protection Policy
Purpose
Kestronics is committed to minimising its environmental impact and promoting sustainability across its operations and supply chains.
Key Principles
1. Sustainability: Kestronics will adopt sustainable practices in all areas of its business, including energy use, waste management, and resource conservation.
2. Compliance: We comply with all applicable environmental laws and regulations and aim to exceed these standards where possible.
3. Reduction of Environmental Impact: We are committed to reducing our carbon footprint and environmental impact by using resources efficiently, reducing waste, and promoting recycling.
4. Supplier Responsibility: Kestronics encourages suppliers and partners to adopt environmentally responsible practices and share our commitment to sustainability.
Purpose
The Business Continuity Management Policy ensures that Kestronics can continue its critical operations and services in the event of disruptions, emergencies, or crises.
Key Principles
1. Risk Assessment: Kestronics regularly identifies and assesses potential risks that could impact business operations, such as natural disasters, cyber-attacks, or supply chain disruptions.
2. Contingency Plans: We maintain up-to-date business continuity and disaster recovery plans to minimise the impact of disruptions and ensure the swift resumption of critical operations.
3. Employee Training: Employees are trained in their roles within the business continuity plan and are aware of the procedures to follow in case of an emergency.
4. Continuous Improvement: Kestronics reviews and updates its business continuity strategy periodically to adapt to emerging risks and ensure readiness.
UK GDPR Policy
Purpose
This policy outlines Kestronics’ commitment to compliance with the UK General Data Protection Regulation (GDPR) to ensure the protection of personal data.
Key Principles
1. Lawful Processing: Kestronics processes personal data lawfully, fairly, and transparently. We only collect and process data necessary for legitimate business purposes.
2. Data Security: We implement appropriate technical and organisational measures to safeguard personal data from unauthorised access, loss, or misuse.
3. Data Subject Rights: Kestronics respects individuals’ rights under GDPR, including the right to access, correct, or request the deletion of their personal data. We have processes in place to respond to such requests promptly.
4. Data Breaches: In the event of a data breach, Kestronics will take immediate steps to mitigate the impact and notify the relevant authorities, where required, as well as the affected individuals.
5. Staff Training: All employees handling personal data receive regular GDPR training to ensure they understand their responsibilities and the importance of data protection
Mark Shirran,
Managing Director
Issued: September 2025
DOWNLOAD or email sales@kestronics.co.uk for a copy.
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