Introduction

Kairos Engineering is committed to conducting its business ethically, responsibly, and with respect for human rights. We recognise that modern slavery, forced labour, child labour, and human trafficking are serious violations of human dignity and fundamental rights, and we adopt a zero-tolerance approach to such practices in all our operations.

As an engineering company operating across Nigeria, including project sites, offices, and supply chains, Kairos Engineering is committed to preventing, identifying, and addressing risks of modern slavery and human trafficking in line with Nigerian laws and international best practices.

Policy Statement

Kairos Engineering prohibits all forms of modern slavery, including forced labour, bonded labour, involuntary servitude, child labour, and human trafficking. We are committed to ensuring that all work carried out on our behalf is voluntary, lawful, and fairly compensated.

No employee, contractor, subcontractor, or supplier shall be subjected to coercion, intimidation, threats, restriction of movement, withholding of identity documents, or any form of exploitation.

Nigerian Legal and Regulatory Context

Kairos Engineering operates in compliance with all applicable Nigerian laws and regulations related to labour and human rights, including:

1. The Constitution of the Federal Republic of Nigeria
2. The Labour Act
3. The Child Rights Act
4. The Trafficking in Persons (Prohibition) Enforcement and Administration Act
5. Relevant guidelines issued by the National Agency for the Prohibition of Trafficking in Persons (NAPTIP)

The company also acknowledges Nigeria’s socio-economic realities and is committed to ensuring that vulnerable groups are protected across all areas of operation.

Scope of Application

This policy applies to:

1. All permanent, temporary, and contract employees
2. Interns, trainees, and apprentices
3. Contractors, subcontractors, labour agents, and suppliers
4. All company operations, project sites, and business activities within Nigeria

Roles and Responsibilities

1. Management is responsible for implementing this policy, allocating appropriate resources, and ensuring effective oversight across operations and supply chains.
2. Supervisors and Project Managers are responsible for monitoring labour practices at worksites, including those of subcontractors, and promptly addressing any concerns.
3. Employees and Contractors are required to comply with this policy and report suspected or actual cases of modern slavery or human trafficking.

Employment Practices

Kairos Engineering is committed to ethical recruitment and employment practices, including:

1. Ensuring employment is freely chosen and based on clear terms and conditions
2. Prohibiting recruitment fees charged to workers
3. Ensuring wages are paid regularly and in accordance with agreed terms and Nigerian labour laws
4. Prohibiting retention of identity documents, passports, or personal belongings
5. Ensuring working hours comply with applicable laws and contractual agreements

Child Labour

Kairos Engineering strictly prohibits the use of child labour in any form. No person below the minimum legal working age under Nigerian law shall be employed or engaged in any company operation or project. Age verification processes are applied during recruitment and contractor engagement.

Supply Chain and Contractor Management

Kairos Engineering expects all contractors, subcontractors, and suppliers to adhere to the principles set out in this policy. Where relevant, the company will:

1. Conduct due diligence on labour practices
2. Include contractual clauses addressing modern slavery and human trafficking
3. Monitor compliance during project execution
4. Take appropriate action where violations are identified

Reporting and Whistleblowing

Employees, contractors, and third parties are encouraged to report concerns or suspicions related to modern slavery or human trafficking through established company reporting or grievance channels. Reports may be made confidentially and without fear of retaliation.

All reports will be investigated promptly and fairly, and appropriate corrective or disciplinary action will be taken where violations are confirmed.

Training and Awareness

Kairos Engineering will promote awareness of modern slavery and human trafficking risks through induction programmes, training sessions, and site briefings, particularly for employees involved in recruitment, procurement, and project management.

Monitoring and Continuous Improvement

The company will periodically review this policy and its implementation to ensure effectiveness, legal compliance, and alignment with industry best practices. Lessons learned, audits, and stakeholder feedback will be used to strengthen controls and prevent future risks.