Human Rights Policy

Statement and Purpose of Policy

Kaleido Projects Ltd (the Employer, we, our or us) is committed to respecting and upholding internationally recognised human rights in all aspects of our business operations. We recognise that businesses have a responsibility to respect human rights, as set out in the United Nations Guiding Principles on Business and Human Rights (UNGPs) and the UN Universal Declaration of Human Rights.
This policy sets out our commitment to ensuring that human rights are respected across our operations, our workforce, and where reasonably practicable, our supply chain.
This is a statement of policy only and does not form part of your contract of employment. We may amend this policy at any time, at our absolute discretion. The Managing Director will review this policy at least annually.

This policy applies to all staff of the Employer, irrespective of seniority, tenure, and working hours, including all employees, directors and officers, consultants and contractors, casual or agency staff, trainees, homeworkers, fixed-term staff and any volunteers (referred to as Staff).
We also expect our suppliers, partners and others we work with to uphold equivalent standards, and we will take reasonable steps to promote this expectation within our supply chain.

We are committed to ensuring that all Staff are treated with dignity and respect at all times. We will not tolerate any form of treatment that violates a person's fundamental human rights, including discrimination, harassment, bullying or victimisation. These matters are further addressed in our Equal Opportunities Policy and Anti-Harassment and Bullying Policy, both contained within this Staff Handbook.

We have a zero-tolerance approach to modern slavery, forced labour, human trafficking and any form of compulsory labour. We will not use, support or knowingly benefit from such practices in any part of our operations or supply chain.
All Staff are encouraged to report any concerns about modern slavery or forced labour immediately to the Managing Director. We will investigate all such concerns promptly and confidentially.
Where required by the Modern Slavery Act 2015, we will publish an annual Modern Slavery Statement, available from the Managing Director.

We are firmly opposed to the use of child labour in any form. We will not engage with any supplier, contractor or third party that we know or reasonably suspect to be using child labour.
For the purposes of this policy, a child is defined as anyone under the age of 16, or the school-leaving age applicable in the relevant country, whichever is higher.

We respect the right of all Staff to freedom of association and collective bargaining in accordance with applicable law. Staff have the right to join or not join a trade union of their choosing, and will not be disadvantaged, penalised or treated less favourably as a result of that choice.

We are committed to ensuring that all Staff receive at least the National Minimum Wage or National Living Wage as applicable, and that working hours comply with the Working Time Regulations 1998. We will not require Staff to work in conditions that are unsafe, unlawful or that undermine their health and wellbeing.
Further details on working conditions, health and safety, and sickness absence are set out in the relevant policies contained within this Staff Handbook.

We respect the right of all Staff to privacy and to the protection of their personal data. Our approach to data protection is set out in the Data Protection and Data Security Policy and the Employee Privacy Notice, both contained within this Staff Handbook.

We are committed to ensuring that human rights are upheld without discrimination of any kind. No person will be treated less favourably on the basis of any Protected Characteristic as defined in our Equal Opportunities Policy, contained within this Staff Handbook.

We will take reasonable steps to identify, prevent and address any human rights risks arising from our business operations. This will include:
a. Considering human rights impacts when making significant business decisions.
b. Reviewing our supply chain where practicable to identify potential risks.
c. Providing relevant training and awareness to Staff as appropriate.
d. Reviewing this policy at least annually and updating it to reflect any changes in legislation, guidance or business activity.

Any member of Staff who has a concern relating to human rights — including suspected modern slavery, forced labour, child labour, discrimination, or any other breach of this policy — is strongly encouraged to raise it as soon as possible.
Concerns may be raised with the Managing Director directly, or through the Employer's Grievance Procedure contained within this Staff Handbook.
All concerns will be treated seriously, investigated promptly and handled with appropriate confidentiality.

Any member of Staff who raises a genuine human rights concern in good faith will be protected from retaliation or victimisation. The fact that a concern has been raised will not affect a Staff member's position within the Employer, even if the concern is not upheld following investigation.
Any Staff member found to have victimised or retaliated against a colleague for raising a human rights concern may be subject to disciplinary action in accordance with our Disciplinary Procedure, contained within this Staff Handbook.

The Managing Director has overall responsibility for this policy and for ensuring that it is implemented effectively across the organisation.
All Staff have a personal responsibility to:
a. Act in accordance with this policy at all times.
b. Treat colleagues, clients, suppliers and visitors with dignity and respect.
c. Report any concerns or suspected breaches of this policy to the Managing Director promptly.
Managers have a particular responsibility to lead by example, to promote awareness of this policy within their teams, and to ensure that any concerns raised are not suppressed or disregarded.

Any breach of this policy will be taken seriously and is likely to result in disciplinary action in accordance with our Disciplinary Procedure, up to and including summary dismissal for gross misconduct.
Staff should also be aware that certain human rights violations, such as modern slavery and trafficking, may constitute criminal offences under UK law, including the Modern Slavery Act 2015 and the Human Rights Act 1998.

The Managing Director will review this policy at least once annually, or sooner if there are changes to relevant legislation or guidance. Staff are encouraged to provide feedback on this policy and to suggest improvements by contacting the Managing Director.

Version 1.0 | Reviewed by: Jareth Reeves | Date: 8th April 2026