Purpose: This policy reflects Kickass Online Ltd's ('KO') commitment to acting ethically and with integrity in all business dealings. KO is committed to ensuring that modern slavery and human trafficking have no place in our business or supply chains, in accordance with the Modern Slavery Act 2015.
Scope: This policy applies to all persons working for or on behalf of KO, including employees, directors, contractors, consultants, agency workers, and business partners.
Our Position
KO has a zero-tolerance approach to modern slavery and human trafficking in any form. Modern slavery encompasses slavery, servitude, forced and compulsory labour, and human trafficking. We are committed to transparency in our own operations and supply chains and to acting with integrity in all our business relationships.
Applicability of the Modern Slavery Act 2015
The Modern Slavery Act 2015 (s.54) requires organisations with an annual turnover of £36 million or more to publish an annual transparency statement. KO's current turnover falls below this threshold and we are therefore not legally required to publish a statutory statement. Nevertheless, we adopt the spirit and principles of the Act as a matter of best practice and in response to client and supply chain expectations.
Our Business and Supply Chains
KO is a UK-based digital agency providing web design, SEO, and AI automation services. Our supply chain is relatively limited and primarily consists of software and platform providers, freelance contractors, and professional services suppliers. While the direct risk of modern slavery in our immediate operations is low, we recognise that risk can exist in extended supply chains and take our due diligence responsibilities seriously.
Supply Chain Due Diligence
KO expects all suppliers, contractors, and business partners to operate to the same ethical standards we apply to ourselves. We will, where practicable:
- Ask new suppliers and contractors to confirm they operate in compliance with the Modern Slavery Act 2015 and equivalent legislation in their jurisdiction
- Avoid knowingly doing business with any supplier or contractor where there is evidence or reasonable suspicion of modern slavery
- Include anti-slavery and human trafficking provisions in contracts with suppliers where appropriate
- Review our supply chain periodically to identify and address modern slavery risks
Recognising Modern Slavery
Indicators that modern slavery may be present include:
- Workers who appear to be under the control of another person and unable to speak freely
- Workers who are paid little or nothing, or whose wages are withheld
- Workers living in overcrowded, substandard, or employer-controlled accommodation
- Workers who appear malnourished, frightened, or are not in possession of their own identity documents
- Unusual working hours or workers who cannot refuse to work
If any employee, contractor, or business partner encounters indicators of modern slavery — whether in KO's operations or those of a supplier — they must report it immediately.
Reporting Concerns
Any concerns about modern slavery in KO's operations or supply chain should be reported to the Data Protection Lead and Director: Pazbi Zavatzki at pazbi@kickassonline.com.
Concerns may also be raised anonymously through KO's Whistleblowing Policy, or externally via the Modern Slavery Helpline (0800 0121 700) or by contacting the National Crime Agency. Employees reporting concerns in good faith will not face any detriment or retaliation.
Responsibility
Overall responsibility for this policy and its implementation rests with the Director of Kickass Online Ltd. All employees and contractors are responsible for reading, understanding, and complying with this policy.
Training and Awareness
KO will ensure that relevant staff are aware of modern slavery risks and their obligations under this policy. Awareness information will be provided on induction and refreshed periodically.
Review
This policy will be reviewed annually. If KO's turnover reaches the £36 million threshold, a full statutory transparency statement will be published in accordance with the Modern Slavery Act 2015 (s.54).
Last reviewed: May 2026.