MODERN SLAVERY ACT TRANSPARENCY STATEMENT

This statement is given on behalf of KBBS Systems

KBBS Systems regards all forms of modern slavery and human trafficking as abhorrent and is committed to ensuring that everyone it deals with is treated with dignity.

We are committed to ensuring that the way we conduct our business and dealings with our suppliers reflects our values.

We strive to ensure that the way we run our business prevents and deters any form of modern slavery and human trafficking from occurring anywhere in our business and supply chain. We are also working with our suppliers to ensure that they uphold the principles in this statement.

Our organisational structure and our business

KBBS Systems is a data analytics software company offering an end-to-end fraud detection platform, enabling organisations to protect themselves against fraud risk.

We are headquartered in Sydney, Australia, but have offices in the United Kingdom.

Our staff

KBBS Systems relies on the commitment and aptitude of our employees to deliver our services and so we regard as essential our commitment to ensuring we operate a fair and ethical workplace.

This applies across all of our offices. As part of this we ensure compliance with all applicable employment legislation relating to employee recruitment and terms and conditions wherever they are based. For example, in the UK, this includes ensuring we obtain right to work evidence and that no UK staff in the UK offices are paid less than the living wage.

Our supply chains

Given the nature of our business, we have a relatively short supply chain. Our software is primarily developed and maintained by our internal development staff.

The development staff are part of KBBS Systems and so subject to the diligence and recruitment standards which apply for all of our employees.

The remainder of our suppliers are providers of our operating systems, services and companies which supply us with hardware and office equipment. These are generally sourced from large reputable suppliers.

Our due diligence processes

It is essential that we have confidence that our contractors, suppliers, and other business partners are working towards meeting the same high standards as we do.  In particular, we are determined to ensure our suppliers treat their own employees and workers with dignity and respect in a fair and ethical environment.

The way in which we engage with suppliers helps to ensure that we can be confident that we remain compliant with the law at all times.

Assessing and managing risk

The importance of identifying, assessing, and monitoring any potential areas of risk in relation to our business and supply chains is intrinsic to the way we operate as a business. This includes considering where we are obtaining services from, the nature of those services, the length of the relationship with the relevant supplier and the nature of what is being supplied.

We are aware that risk can arise throughout the supply chain and we work to put practices in place to assess and mitigate against that risk. In that context we carefully consider our suppliers and particularly ensure that, to the extent possible, appropriate contractual obligations are put in place to bind our suppliers to compliance with applicable legal requirements.

Our Policies

As a business we have implemented a number of policies designed to ensure that the way we work, and the way those working with us conduct themselves, is reflective of the principles and standards we hold ourselves to.

The policies aim to provide recognition of our duty of care in line with Human Rights Commission code of practice.

Our policies encourage the importance of legal compliance and an understanding of the modern slavery act.

The policies set out the standards we expect to be set, including building and maintaining a culture of compliance, and preventing, detecting and responding to compliance problems. This is of course broader than Modern Slavery Act compliance but applies to help us to reduce the risk of modern slavery issues arising and provides a mechanism for dealing with concerns if they do.

These policies are supported by separate whistle-blower and Complaint Policies. Together these help us to set the standard we expect, ensure that our staff are best placed to help us achieve it, and importantly feel supported to do so.

Training

It is important to us that our employees are aware of the issues surrounding modern slavery and support our values.

As part of achieving ongoing improvements, we are intending to continuously evaluate our education program to ensure our actions are consistent with industry practices.

We intend to continue to engage with our key suppliers and hope to improve their awareness of modern slavery issues and risks. We will continue to periodically review our policies and suppliers to ensure compliance with the relevant slavery legislation.

We will also continue to enhance our collaboration with our relevant entities to combat modern slavery.

Closing

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and constitutes KBBS Systems's slavery and human trafficking statement for the financial year ending 30th June 2021.

This statement is approved by the directors of KBBS Systems and made pursuant to the UK's Modern Slavery Act 2015 and the Modern Slavery Act 2018 of Australia and constitutes KBBS Systems's slavery and human trafficking statement for the financial year ending 30th June 2021.