Modern Slavery Statement.

Introduction

Kitwick ("Kitwick", "we", "us", or "our") is committed to conducting our business responsibly, ethically and with respect for human rights.

We do not tolerate modern slavery, human trafficking, forced labour, bonded labour or any other form of exploitation within our business or in the supply chains and business relationships connected with our services.

This Modern Slavery Statement explains the approach we take to preventing modern slavery and human trafficking in connection with our business.

About Kitwick

Kitwick provides web hosting, WordPress hosting, domain registration and related digital services.

Our services may involve relationships with third-party providers, including hosting infrastructure providers, data centres, domain registrars, software providers, payment providers and other technology suppliers.

We recognise that responsible management of these relationships is important to maintaining ethical business practices.

Our Commitment

Kitwick is committed to:

• Respecting fundamental human rights.
• Operating our business ethically and responsibly.
• Not knowingly supporting forced or compulsory labour.
• Not knowingly supporting human trafficking.
• Treating people fairly and with dignity.
• Expecting appropriate ethical standards from relevant suppliers and business partners.
• Taking concerns relating to modern slavery seriously.
• Reviewing our practices where risks or concerns are identified.

We expect employees, contractors, suppliers and relevant business partners to share these principles.

Modern Slavery and Human Trafficking

For the purposes of this statement, modern slavery includes practices such as:

• Forced labour.
• Compulsory labour.
• Bonded or debt labour.
• Human trafficking.
• Servitude.
• Slavery.
• Other forms of exploitation where a person is unable to freely leave or control their employment or situation.

Kitwick does not knowingly engage in or support these practices.

Our Employees

We aim to provide a working environment in which individuals are treated fairly, respectfully and lawfully.

Where applicable, our employment practices are intended to support:

• Voluntary employment.
• Appropriate working conditions.
• Fair treatment.
• Respect for individual rights.
• Freedom from discrimination and harassment.
• Appropriate remuneration and employment terms.
• A safe environment in which concerns can be raised.

Employees should not be required to surrender identification documents or be prevented from leaving employment unlawfully.

Recruitment

Kitwick aims to conduct recruitment responsibly and transparently.

Where recruitment agencies, contractors or other third parties are used, we expect them to operate lawfully and ethically.

We do not knowingly support recruitment practices involving:

• Forced labour.
• Recruitment fees imposed unlawfully on workers.
• Deception regarding employment conditions.
• Retention of personal identity documents.
• Threats or coercion.
• Human trafficking.

Our Supply Chain

Kitwick operates in the technology and digital services sector and may rely on third-party suppliers to deliver parts of our services.

These may include:

• Hosting and infrastructure providers.
• Data centre providers.
• Domain registrars.
• Software providers.
• Security providers.
• Backup providers.
• Payment service providers.
• Communications providers.
• Professional service providers.

We recognise that modern slavery risks may exist within wider technology and infrastructure supply chains.

We therefore aim to consider ethical and human-rights considerations when establishing and maintaining relevant supplier relationships.

Supplier Expectations

Where appropriate, Kitwick expects suppliers and business partners to:

• Comply with applicable laws.
• Respect human rights.
• Avoid forced or compulsory labour.
• Avoid human trafficking.
• Treat workers fairly and respectfully.
• Maintain appropriate employment practices.
• Take reasonable steps to identify and address modern slavery risks.

Where we become aware of credible concerns regarding a supplier's practices, we may investigate the matter and consider appropriate action.

Risk Assessment

Kitwick recognises that the risk of modern slavery can vary depending on:

• The type of service being provided.
• The location of the supplier.
• The nature of the workforce involved.
• The complexity of the supply chain.
• The use of subcontractors.
• The level of visibility we have over the supplier's operations.

We aim to take a proportionate approach to identifying and addressing potential risks.

Due Diligence

Where appropriate and proportionate to the relationship, Kitwick may consider information about a supplier's:

• Business practices.
• Legal and regulatory compliance.
• Ethical policies.
• Employment practices.
• Supply-chain practices.
• Approach to human rights.
• Modern slavery policies or statements.

The level of due diligence may depend on the nature and significance of the supplier relationship.

Raising Concerns

Kitwick encourages employees, contractors, suppliers and other relevant parties to raise concerns if they believe modern slavery, human trafficking or other serious exploitation may be taking place in connection with our business or supply chain.

Concerns should be raised with Kitwick using the appropriate contact details provided at the end of this statement.

Concerns will be taken seriously and reviewed appropriately.

Responding to Concerns

Where a credible concern is identified, Kitwick may take appropriate steps depending on the circumstances.

These may include:

• Investigating the concern.
• Requesting additional information.
• Engaging with the relevant supplier or business partner.
• Reviewing the relevant relationship.
• Taking corrective action where appropriate.
• Suspending or terminating a supplier relationship where serious concerns are identified.
• Reporting matters to appropriate authorities where required or appropriate.

Our response will depend on the nature and seriousness of the concern.

Training and Awareness

Kitwick recognises that awareness is an important part of preventing modern slavery.

Where appropriate to the size and nature of our organisation, we aim to ensure that relevant personnel understand:

• What modern slavery is.
• The potential risks associated with modern slavery.
• How concerns can be identified.
• How concerns should be reported.
• The importance of treating workers and business partners ethically.

As our organisation develops, we may introduce additional training or awareness measures where appropriate.

Employee Responsibilities

Employees and individuals working on behalf of Kitwick are expected to:

• Act ethically and responsibly.
• Follow applicable company policies.
• Treat others with dignity and respect.
• Raise concerns about suspected exploitation.
• Avoid knowingly entering into inappropriate business relationships.
• Cooperate with relevant investigations.

No individual should ignore or conceal a serious concern relating to modern slavery.

Business Partners and Contractors

We expect contractors, consultants and other business partners working with Kitwick to conduct themselves responsibly and comply with applicable laws.

Where appropriate, contractual arrangements may require business partners to meet relevant legal, ethical or compliance requirements.

Monitoring and Review

Kitwick will review this statement and our approach to modern slavery periodically.

Reviews may consider:

• Changes to our business.
• Changes to our suppliers.
• Changes to our supply chain.
• Identified risks.
• Reported concerns.
• Changes in applicable legal or regulatory requirements.
• Lessons learned from relevant incidents or investigations.

Where appropriate, we may introduce additional measures to strengthen our approach.

Accountability

Responsibility for maintaining Kitwick's approach to modern slavery rests with the appropriate management of the business.

Management is responsible for ensuring that relevant concerns are considered and that appropriate action is taken where necessary.

Our Ongoing Commitment

Kitwick recognises that preventing modern slavery is an ongoing responsibility.

As our business and supply-chain relationships develop, we will continue to consider how we can improve our approach to:

• Human rights.
• Ethical business practices.
• Supplier relationships.
• Risk identification.
• Employee awareness.
• Reporting and investigation.

We remain committed to conducting our business responsibly and to taking reasonable steps to prevent modern slavery and human trafficking in connection with our operations and supply chain.