Human Rights Policy

As the world's largest IT infrastructure services provider, people are at the heart of our business. Kyndryl has a great responsibility to ensure our operations promote a sustainable and just future for all, and we’re committed to making that vision a reality. Our mission is to power human progress through modernizing and managing the world's mission-critical systems and services and to do so responsibly and equitably. We believe technology should be used to empower people to drive the innovations needed to address the pressing problems of today and tomorrow. Respect for all human rights across our operations, products services and relationships is fundamental to the success of that goal. As a newly independent company with operations in over 60 countries, Kyndryl commits to respecting all human rights - civil, cultural, economic, political, and social.

Kyndryl looks to international standards for applicable guidance on our strategy and reporting, such as the Universal Declaration of Human Rights, and the following international human rights standards:

• International Covenant on Civil and Political Rights
• International Covenant on Economic, Social and Cultural Rights
• International Labour Organization’s Declaration on Fundamental Principles and Rights at Work
• Convention on the Elimination of All Forms of Discrimination against Women
• Convention on the Rights of the Child
• United Nations Declaration on Human Rights Defenders

Kyndryl commits to annually reviewing our approach and policies regarding human rights through a comparison against international standards and industry best practices as they evolve.

Developing our Human Rights Policy

Kyndryl’s vision is to be a catalyst for positive change at the intersection of people and technology. To ensure equitable operations, Kyndryl aims to evaluate policy issues like data privacy, cybersecurity, and data stewardship, along with legacy operational issues like supply chain management through the lens of human rights and how they may be impacted by such technologies and operations. By raising the bar of our own technologies and operations, we hope to encourage the broader technology industry to bring human rights issues to the forefront of their ESG agendas, mitigating potential harms of technology on people around the world. We intend to regularly assess our technologies and operations to identify salient human rights issues and demonstrate continued progress as part of Kyndryl’s annual ESG and corporate responsibility reporting.

Kyndryl's human rights policy was developed with a human-centered approach to identify the most important ways technology affects people and how, as a technology services company, we can reduce any adverse effects. We assembled a cross-functional Kyndryl team, including corporate social responsibility, human resources, procurement and legal, with additional external support from human rights experts to build a policy that addresses human rights issues across civil, cultural, economic, political, and social domains. As part of our broader human rights strategy, we intend to engage additional stakeholders and rights holders to ensure our policy is aligned with human rights priorities and best practices.

Identification of Human Rights Issues

As a technology services company, Kyndryl’s success depends on the physical and psychological safety of each of our employees and the suppliers who support our operations, products and services. Based on the results of a Materiality Assessment, stakeholder research, and the nature of our business as a services company, we concluded that the use and application of our products and services is most impactful on human rights. Additionally, supply chain and diversity and inclusion issues were prioritized as part of our broad human rights strategy. The full results of our Materiality Assessment are posted on our Corporate Social Responsibility page on Kyndryl.com. Kyndryl intends to monitor human rights risks through future human rights assessments and adjust our priorities as necessary.

Human Rights Policy

Our goal is to protect and respect the human rights of all people across our operations and share related best practices with our ecosystem of customers, suppliers, partners, and employees. We commit to proactively avoiding human rights abuses and complicity in abuses by other participants in our ecosystem outlined in our approach below.

Internal Kyndryl Policies to Address Human Rights

Kyndryl has established policies to govern our corporate behavior around labor, health and safety, community engagement, and child labor. For example, Kyndryl will not use forced, bonded (including debt bondage), indentured labor or involuntary prison labor.  Kyndryl will not use child labor. Kyndryl will comply with all laws regarding minimum wages, safe working environments and other elements of employment. In line with Kyndryl's Global Employment Standards and Kyndryl Code of Conduct, Kyndryl commits to upholding the most stringent international human rights standards if company and international or national standards are not aligned. Further details on the procedures and controls we have in place to address human rights are defined later in this policy.

Kyndryl has established a formal grievance and remedy process to enable employees and suppliers to report any concerns or issues. This forum is anonymous and can be used to report human rights or any other ethical violation. Kyndryl has a strict non-retaliation policy to protect and encourage those who raise issues to the attention of management.

Procedures Applicable to Kyndryl’s Suppliers

As of January 1, 2022, Kyndryl became a signatory of the Responsible Business Alliance (RBA). This marks an important step in our commitment to human rights. Under the RBA Code of Conduct Kyndryl requests suppliers to refrain from the direct or indirect use of forced labor or any forms of human trafficking and to verify/certify that their supply chains address these issues. Kyndryl commits to requesting its suppliers certify compliance with laws regarding slavery and human trafficking in alignment with local laws and the RBA Code of Conduct. Today, as part of our Supplier Code of Conduct, we have processes in place for suppliers to report on any confirmed or suspected unlawful or unethical situations involving Kyndryl to the Kyndryl Procurement Ombudsman.

RBA offers training and tools to support compliance by identifying countries that are at an elevated risk for human rights violations. By evaluating compliance at a regional level based on risk level, Kyndryl can help ensure we effectively manage and mitigate risks across the diverse regions in which we operate, To assess compliance in the future and avoid complicity in abuses by suppliers, Kyndryl intends to develop its own audit process that incorporates RBA guidelines, requires root cause to determine recommended corrective actions for all code noncompliance, engages a cross-section of companies in countries where the risk of noncompliance is elevated, and establishes a grievance procedure. If a supplier is found to violate the RBA Code, the supplier must take corrective actions to remediate the violation or risk termination. In the future, Kyndryl intends to establish a performance-based metric to assess suppliers on their compliance with the RBA Code that will considered when deciding to keep existing suppliers and awarding future work.

Policy: Methods of Compliance

Audits & Allegation Review

Kyndryl will require root cause analysis and corrective actions to be implemented for all noncompliance with its human rights standards and will establish a grievance procedure described below to address allegations of human rights abuses among our employees, and suppliers.  

Training

As part of our commitment to operating responsibly, Kyndryl requires all our global employees to annually certify they have completed ethics training in the Kyndryl Code of Conduct. More information on the Kyndryl Code of Conduct and ethics guidelines can be found here. Today, Kyndryl offers training on emerging technology-focused policy issues like data privacy, cybersecurity and data stewardship.

In addition to our employee training on the Kyndryl Code of Conduct, we offer our procurement and supply chain professionals training through our agreement with RBA. In the future, we intend to expand our training to include opportunities for executives and our broader employee base to learn about human rights issues relevant to the technology industry.

Governance Structure

Kyndryl's approach to human rights depends on a strong governance model to ensure that our policies and practices are implemented effectively. Kyndryl’s VP of Global Corporate Affairs is responsible for overseeing human rights related activities, conducting an annual review of Kyndryl’s initiatives under this policy, and monitoring evolving industry standards. Kyndryl’s VP of Global Corporate Affairs serves as the chair of Kyndryl’s ESG Executive Committee which includes members of Kyndryl’s C-Suite and other executive leaders. This Committee convenes monthly to review progress on ESG issues.

Going Above and Beyond Respecting Human Rights: Increasing awareness across our industry

Kyndryl is committed to raising the standard of our ecosystem to increase awareness of human rights issues and how to mitigate them through training and thought leadership.

This policy marks an important step toward addressing human rights issues. Kyndryl intends to collaborate with our broader ecosystem, nonprofits, and academic institutions to better understand the emerging human rights issues at the intersection of people and technology. Through these partnerships, we hope to increase awareness of human rights issues for our employees, suppliers, customers, and the millions of people around the world who depend on our technology each day.

Frequently Asked Questions

What are human rights?

Human rights are rights inherent to all human beings, regardless of race, sex, nationality, ethnicity, language, religion, or any other status. Human rights include the right to life and liberty, freedom from slavery and torture, freedom of opinion and expression, the right to work and education, and many more.  Everyone is entitled to these rights, without discrimination.

A Human Rights policy is a public statement confirming an organizations’ commitment to respect international human rights standards and our first Human Rights policy represents an important step toward achieving our goal of being a catalyst for positive change at the intersection of people and technology.

What is Kyndryl’s Human Rights Policy?

Kyndryl's Human Rights Policy was developed with a human-centered approach to identify the most important ways our operations affect people and how, as a technology services company, we can reduce any adverse effects.

Kyndryl’s vision is to be a catalyst for positive change at the intersection of people and technology. To ensure equitable operations, Kyndryl’s Human Rights Policy looks at issues like data privacy, cybersecurity, and data stewardship, along with legacy operational issues like supply chain management, through the lens of human rights and how they may be impacted by such technologies and operations.

We hope to encourage the broader technology industry to bring human rights issues to the forefront of their ESG agenda, mitigating potential harms of technology on people around the world. We intend to further assess our operations to identify salient human rights issues, demonstrate continued progress, and share more detail on our progress as part of Kyndryl’s annual ESG and corporate responsibility reporting. 

How are human rights relevant to Kyndryl’s business? 

As a services company, our business success depends on the physical and psychological safety of each of our employees and the suppliers who support our operations, products and services. Based on the results of a Materiality Assessment, stakeholder research, and the nature of our business as a services company, we recognize that respecting human rights is an essential element of Kyndryl’s Environmental Social Governance (ESG) strategy to ensure a sustainable and inclusive futures for all.

As Kyndryl’s mission is to power human progress through modernizing and managing the world's mission-critical systems and services, we are committed to doing so responsibly and equitably. We believe technology should be used to empower people to drive the innovative changes needed to address the pressing problems of today and tomorrow and aim to share and encourage related best practices with our ecosystem of customers, suppliers, and partners throughout our business.Respect for all human rights across our operations, products and services is fundamental to the success of that goal.

What is the process to report human rights violations and complaints? How does Kyndryl address human rights complaints?

Kyndryl has established a formal grievance and remedy process to enable employees and suppliers to report any concerns or issues. This forum is anonymous and can be used to report human rights or any other ethical violation. 

As part of our Supplier Code of Conduct, Kyndryl also has processes in place for suppliers to report on any confirmed or suspected unlawful or unethical situations involving Kyndryl to the Kyndryl Procurement Ombudsman.