Modern Slavery and Human Trafficking Policy

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Modern Slavery and Human Trafficking Policy

The Kaden Group

1. Introduction

The Kaden Group is committed to conducting business ethically and responsibly. We adopt a zero-tolerance approach to modern slavery, human trafficking, forced labour, and exploitation in all forms.

This policy outlines our efforts to prevent and address these risks within our operations and supply chains and is aligned with:

  • UK Modern Slavery Act 2015
  • Australian Modern Slavery Act 2018
  • California Transparency in Supply Chains Act 2010
  • UN Guiding Principles on Business and Human Rights
  • ILO Forced Labour Conventions (No. 29 and No. 105)
  • Universal Declaration of Human Rights

This statement applies to all companies and subsidiaries under The Kaden Group.

2. Our Business and Supply Chains

The Kaden Group operates within the golf, travel, and hospitality industries, providing luxury golf travel and event experiences. Our supply chains include:

  • Airlines, ground transport providers, and logistics partners
  • Hotels, golf resorts, and event venues
  • Third-party service providers (marketing, technology, catering)
  • Contractors, seasonal staff, and international agents

We recognise that the global nature of our supply chain can present risks related to human rights and labour exploitation, and we are committed to proactively managing these risks.

3. Our Commitment

  • Zero tolerance for modern slavery or human trafficking in any form.
  • Adherence to international human rights principles and labour standards.
  • Requiring suppliers, contractors, and partners to comply with the same ethical obligations.
  • Continuous improvement of policies and practices to identify and mitigate risks.

4. Due Diligence and Risk Assessment

To address modern slavery risks, we undertake:

  • Pre-contract due diligence on suppliers and partners.
  • Risk assessments of countries, industries, and suppliers with higher vulnerability to exploitation.
  • Inclusion of anti-slavery and human rights clauses in supplier agreements.
  • Ongoing monitoring and audits, with corrective actions where necessary.

5. Training and Awareness

We provide training to relevant staff — particularly in procurement and supply chain management — to help identify signs of modern slavery and understand reporting obligations. Awareness materials are reviewed regularly to reflect legal and best-practice updates.

6. Reporting Concerns

We encourage employees, suppliers, and third parties to report any concerns regarding modern slavery via confidential reporting channels. We guarantee:

  • Non-retaliation for whistleblowers.
  • Thorough and prompt investigation of all reports.
  • Corrective action, including terminating relationships with non-compliant partners.

7. Governance and Review

This policy is reviewed annually by senior management and updated in line with legal developments and international standards. A formal Modern Slavery Statement is published each year in accordance with applicable legislation.

Approval

This policy has been approved by the Board of Directors of The Kaden Group and will be published on www.thekadengroup.com.

Date of Approval: 04/08/2025
Signed:
Deniz Gurlersan
General Manager
The Kaden Group