This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by KPPES Ltd. during the financial year ending 31st August 2026 to identify and manage the risk of slavery, servitude, forced or compulsory labour and human trafficking (Modern Slavery) within our business and labour supply chains.
It also reflects our continuing responsibility to remain alert to the risk of Modern Slavery and to maintain proportionate controls designed to prevent, identify and respond to potential worker exploitation.
Our business and supply chains
Key Portfolio is a payroll and employment service used by a large number of contractors, including supply teachers and IT consultants. These individuals are employed by KPPES Ltd. Assignments are generally sourced through employment businesses and carried out at workplaces across the UK, such as schools and offices. In our industry, KPPES Ltd. is known as an Umbrella Company.
Our labour supply chains principally involve the employment businesses through which assignments are introduced, the end clients receiving our employees’ services and, where applicable, other intermediaries within the contractual chain.
Risk of Modern Slavery
We consider the overall risk of Modern Slavery within our own operations to be low. We operate in the UK and our direct supply arrangements are relatively straightforward. However, we recognise that labour supply chains can present risks of worker exploitation and that no organisation should assume that Modern Slavery cannot occur within its operations or supply chains.
We therefore maintain controls across our employment business onboarding, employee onboarding, identification and Right to Work, employee information, bank details and payroll activities. These controls support our wider employment, immigration and tax compliance obligations and also help us identify circumstances which may indicate worker exploitation or Modern Slavery.
An individual anomaly or warning sign does not, by itself, indicate that Modern Slavery is taking place. Where something unusual is identified, we consider the circumstances and undertake further enquiries where appropriate, with particular attention given to multiple or connected warning signs.
Employees
Our employees have several parties involved in their working arrangements – us, their employment business and their end-user client. This provides employees with a number of potential routes through which they may raise concerns. An important part of our role is to be an approachable, supportive and professional point of contact for our employees, and we are in regular communication with them.
We encourage employees to come to us with concerns or worries relating to their employment or working arrangements. We would protect any whistleblower who came to us with information regarding Modern Slavery. Our Employee Handbook contains our Whistleblowing Policy and our Modern Slavery guidance and associated processes are kept under review.
We carry out appropriate identification and Right to Work checks before employment commences and monitor time-limited Right to Work throughout employment where applicable. Documentation is obtained directly from the prospective employee rather than through a recruitment agency or other third party.
We also maintain controls over employee contact information, personal information and bank details. Bank details, including changes, must be provided or confirmed directly by the employee. We undertake checks designed to identify unusual duplication or patterns which may warrant further review.
Our payroll controls help to ensure employees are paid correctly and that deductions are properly authorised or permitted. Our software-based National Minimum Wage control prevents payroll from being processed where an employee’s pay would fall below the applicable statutory minimum rate. Employees are provided directly with an itemised payslip setting out their gross pay, deductions and net pay.
Employees are free to leave our employment in accordance with their contractual arrangements and can contact us directly at any time if they have concerns about their employment or working arrangements.
Employment business and supply chain due diligence
We have long-standing relationships with hundreds of employment businesses and other suppliers across the UK. When establishing new employment business relationships, we undertake due diligence which includes verifying the legal entity, Companies House details, trading status and named contacts.
We remain alert to circumstances such as unclear or unnecessarily complex labour supply chains, difficulty establishing the identity or legitimacy of parties within a chain, unexplained changes of contracting entity, or reluctance or inability to provide clear assignment or end-client information where this would reasonably be expected to be known.
We expect the organisations with which we work to share our zero-tolerance approach to Modern Slavery. Where information gives us reason to believe that an organisation may be involved in worker exploitation or Modern Slavery, the matter would be investigated and the appropriateness of the relationship reviewed.
Staff awareness, monitoring and escalation
Our internal Modern Slavery monitoring process is communicated to relevant employees involved in employment business onboarding, employee onboarding, compliance and payroll activities. Relevant employees are expected to be familiar with potential warning signs and to raise concerns identified through their normal activities in accordance with our internal review and escalation process.
Where concerns arising from a warning sign cannot be satisfactorily resolved, or information suggests that an employee may be experiencing exploitation, coercion, forced labour or another form of Modern Slavery, the matter is promptly escalated. The appropriate response is determined according to the circumstances and may include speaking privately with the employee, preserving relevant records, obtaining specialist or legal advice, reviewing relationships within the labour supply chain and making or facilitating an appropriate report or referral to the relevant authority or support organisation.
Where there is an immediate risk of harm or danger, the matter would be reported to the emergency services without delay.
To date, our monitoring controls have not identified any confirmed or suspected instances of Modern Slavery or worker exploitation within our employment or labour supply arrangements. Our monitoring processes and associated controls are kept under review and updated where appropriate to reflect changes in our operations, identified risks, regulatory requirements or lessons arising from any concerns investigated.
This statement was approved by the Board of Directors of KPPES Ltd.
Signed
Gary Walker FCCA
Director, KPPES Ltd.
September 2026