Introduction

This statement is published in accordance with section 54(1) of the Modern Slavery Act 2015. It sets out the steps taken by Kinaxia Limited and its subsidiary companies (“the Group”) to prevent modern slavery and human trafficking within its business operations and supply chains during the financial year 1 January 2025 to 31 December 2025. A list of the Group’s current subsidiaries is included in the Schedule.

Operating within the transport and warehousing sector, the Group recognises its responsibility to take a robust, transparent and risk-based approach to identifying, preventing and addressing modern slavery and human trafficking risks.

The Group is committed to acting ethically and responsibly, protecting human rights, preventing labour exploitation and supporting the principles set out in Kinaxia’s ESG, Ethical Trading, Whistleblowing, Employee Code of Conduct and Right to Work policies.

 

The Group Structure and Supply Chains

This statement applies to all companies within the Group.

The Group provides transport and warehousing services to external customers, including the storage, handling, picking and packing of customer products across its UK operations.

 

Countries of operation and supply

The Group currently operates in the UK.

The Group’s principal purchases include fuel, office equipment, uniforms, tyres and vehicle parts, including items sourced from European manufacturers.

 

High-risk activities

The Group recognises that the use of temporary agency labour and subcontracted transport or warehousing services may present an increased risk of modern slavery or labour exploitation if not appropriately managed.

The Group’s workforce is primarily made up of drivers, warehouse colleagues, workshop colleagues and administrative colleagues. While the Group operates in the UK and its direct operational exposure is considered limited, it remains committed to maintaining appropriate controls across its employment practices and supply chain relationships.

 

Responsibility

Responsibility for the Group’s anti-modern slavery and human trafficking framework is allocated as follows:

• Policies: the Group HR Director is responsible for developing, maintaining and reviewing relevant employment policies and supporting processes to ensure compliance with UK employment legislation, including National Minimum Wage requirements.
• Risk assessments: the Group Board has overall responsibility for human rights, governance and strategic oversight. Senior management teams within each Group company are responsible for monitoring local operational risks and maintaining appropriate controls.
• Investigations and due diligence: the Group will take all concerns or suspicions of modern slavery and human trafficking seriously and investigate them appropriately. There were no known or suspected instances of modern slavery or human trafficking during the financial year ending 31 December 2025.

 

Relevant Policies

The Group maintains policies that support the identification, prevention and reporting of modern slavery risks and promote ethical, lawful and responsible business conduct:

• Whistleblowing Policy: the Group encourages colleagues, customers, suppliers and other business partners to report concerns relating to its operations or supply chains, including circumstances that may indicate an increased risk of modern slavery or human trafficking. The procedure is intended to support accessible reporting without fear of retaliation.
• Employee Code of Conduct: the Code sets out the standards of conduct and behaviour expected of colleagues when representing the Group, including ethical decision-making, lawful conduct and respectful working relationships.
• Right to Work Policy: the Group carries out appropriate right to work checks to confirm that each colleague is legally eligible to undertake the work for which they are employed.
• ESG and Ethical Trading Policies: the Group’s ESG and ethical trading commitments support responsible governance, protection of human rights, prevention of labour exploitation, fair treatment and sustainable supply chain practices, and are informed by the principles of the Ethical Trading Initiative Base Code.

 

Due Diligence

The Group undertakes ongoing due diligence and risk assessment across its operations and supply chains, including when appointing new suppliers and when periodically reviewing existing supplier relationships.

The Group also uses independent Sedex SMETA audits, where appropriate, to assess the effective implementation of policies, procedures and labour standards across relevant operations and supply chain activities.

Where appropriate, customer and supplier contracts include obligations to comply with applicable laws, standards and ethical trading expectations, including alignment with the ETI Base Code. If the Group becomes aware of a breach, it may exercise contractual rights, including termination, and may make regulatory or criminal reports where required.

 

Training

The Group recognises the importance of training, communication and awareness in helping colleagues identify, prevent and report modern slavery and human trafficking risks.

During 2025, the Group trialled a training course to strengthen awareness of modern slavery and human trafficking risks and reporting responsibilities. The course is planned for wider launch during 2026.

The Group also supports employee voice and engagement through appropriate colleague forums, communication channels and engagement practices. These mechanisms help colleagues raise concerns, share feedback and contribute to the continuous improvement of policies, procedures and workplace standards.

 

Approval

This statement was approved by the Group Board of Directors on 30 June 2026 and will be reviewed and updated annually.

 

Graham Cox
Group Chief Executive Officer, 1 July 2026