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This statement sets out the Company’s actions aimed at taking measures to ensure no slavery or human trafficking occurs in its business and wider supply chain. The Company is committed to improving its practices to combat slavery and human trafficking. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) and constitutes teh Company’s slavery and human trafficking statement in relation to its actions and activities during the financial year 1 January 2019 to December 2020.

Organisational structure and business

The Company operates as a consulting, product development and data analytics company offering consulting services, such as artificial intelligence transformation strategy. It offers technology services in robotic process automation, data intelligence, natural language processing, digital product development, nutritional health data analysis, health patient experience and digital health consumerism.

Our Supply Chains

The Company’s supply chains include software developers, professional services, technology partners, I.T. and office equipment suppliers, facilities services and data hosting services. We are based in the UK, EU, India and the US. Our supply chain is low risk and non-complex in structure.

Our policies on slavery and human trafficking

Our position on slavery and human trafficking is clear as we have current long established policies, processes and practices in place to prevent this within our business operations and supply chains. We continuously look at ways to enhance these processes and we currently undertake the following measures.

It is now our policy to require our suppliers to adhere with our supplier code of conduct (the “Code”) which amongst other governance and compliance obligations made reference to in the Act, sets out the minimum behaviours, standards and practices we expect to see from our suppliers and amongst other obligations prohibits forced labour, discrimination and child labour, ensures supplier working conditions are safe and that workers are treated with respect and dignity with the aim of preventing slavery and human trafficking taking place anywhere in our supply chains or business operations with a view to helping in the global effort to reduce these practices. The Code is published on our external website and all new suppliers are required to read and acknowledge this as part of the on-boarding process.

Our Purchase Order Terms and Conditions and Global Supplier Agreements contract terms require our suppliers and vendors to comply with all applicable law and have recently been updated to include compliance with the Act and Code.

We practice responsible procurement. Contracts signed with major suppliers central or regional are encouraged to mobilise in favour of human rights through our internal “CSR Procurement Charter” and “CSR Procurement Questionnaire” which are sent to all suppliers during the tendering process. Suppliers are also sent CSR Procurement guidelines and their actions and commitment to CSR is tracked through our internal procurement portal and only suppliers who have conducted the self-assessment may progress through to the selection process. Our major suppliers are encouraged to take part in an external audit that assesses suppliers corporate social responsibility standards including health and safety, environment, ethics etc. so that we can measure and monitor the suppliers progress and achievements with our compliance policies.

We comply with all relevant UK employment laws and have internal policies in place to prevent slavery and human trafficking included in the employee handbook which is circulated to all employees and covers recruitment, health & safety, harassment, anti-bribery, equal opportunities and diversity. Our employees have access to a confidential whistleblowing process for raising concerns and we continue to increase awareness amongst employees through training on issues relating to slavery and human trafficking so that they may report any concerns as they arise. Since the Act came in to force, we have drafted an ANti-Slavery & Human Trafficking policy which has been included in the employee handbook, which all employees have access to and is communicated to all new joiners during the induction process.

The Company is a signatory of the Global Compact 10 Principles of the United Nations which requires the Company’s Chief Executive Office to provide a written pledge on an annual basis that the Company will observe and uphold the 10 Principles of United Nations Global Compact, which exist to protect universal human rights and the elimination of all forms of forced and compulsory labour and child labour. The Company is committed to ensuring these principles are upheld across all its business practices.

Risk Assessment and Due Dilligence

With the introduction of the Act, we assessed our supply chain for potential areas of increased risk of slavery and human trafficking. As part of our initiative to identify and mitigate the risk of slavery and human trafficking in our supply chains, we conducted a review of our major suppliers and identified those in high risk areas.

We as our existing and new suppliers to complete a self-assessment questionnaire detailing any action, procedures, policies and practices carried out by their organisation to prevent slavery and human trafficking. Suppliers must agree to adhere to the Code, a copy which is attached to the questionnaire and they are also required to annually certify a declaration form confirming understanding and compliance with the Code and the Act.

Suppliers who assessed to be high risk will get a more detailed review of their questionnaires to identify areas of concern that may conflict with our Code or the Act, better understand the risk, provide feedback and agree steps to put in place to improve their processes. High risk suppliers that will receive special attention include companies that operate using temporary low skilled workers, operate outside the UK or EEA and/or manufacture or trade in raw materials outside the UK or EEA.

We continually assess our compliance with the Act through the mechanisms of an annual audit carried out by our legal, procurement and internal audits teams and/or external outsourced partners.

Further Steps

We will periodically review the effectiveness of our processes and systems and any changes will be reflected in future annual statements.

This statement has been approved by the board of directors of the Company.

Written by Oliver Cogan, Director
Date 15 March 2019

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