Komet Capital Limited (Komet) is committed to acting ethically, with integrity and in full compliance with applicable laws. We recognise that modern slavery, human trafficking, forced labour and child labour are global issues, and we take a zero-tolerance approach to any form of exploitation in our operations or supply chain.
1. Our commitment
We are committed to ensuring that our business activities and those of our partners, suppliers, agents and intermediaries are conducted free from modern slavery and human trafficking. We expect the same standards from everyone we work with.
2. Scope
This policy applies to all employees, directors, contractors, consultants, agents, suppliers and any other parties acting on behalf of Komet Capital Limited (Komet). It covers all jurisdictions in which we operate and all business relationships we enter into.
3. Definitions
For the purpose of this policy, modern slavery includes but is not limited to:
- Slavery, servitude and forced or compulsory labour.
- Human trafficking, including the recruitment, transportation or transfer of individuals by means of coercion, deception or abuse of vulnerability.
- Child labour that is exploitative or inconsistent with applicable minimum-age laws.
- Any other practice that deprives a person of their liberty, dignity or fair remuneration.
4. Due diligence
We assess the risk of modern slavery and human trafficking in our operations and supply chain through proportionate due diligence. This may include:
- Reviewing suppliers and counterparties for compliance with applicable labour laws.
- Where appropriate, including contractual obligations that prohibit modern slavery and human trafficking.
- Monitoring and reviewing relationships on an ongoing basis.
5. Reporting concerns
We encourage anyone who suspects or becomes aware of modern slavery, human trafficking or related misconduct in connection with our business to report it promptly. Reports can be made via our contact page or directly to compliance personnel. Concerns will be taken seriously and investigated confidentially, and individuals will not suffer retaliation for raising concerns in good faith.
6. Training and awareness
We provide appropriate training and guidance to relevant staff to help them identify and respond to risks of modern slavery and human trafficking. We promote awareness of this policy across our organisation and business relationships.
7. Review
This policy is reviewed at least annually and updated as necessary to reflect changes in our business, legal obligations and best practice. Responsibility for its oversight sits with senior management.
8. Contact
If you have any questions about this policy or wish to report a concern, please contact us via our contact page.