Anti-Slavery Policy Statement

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps that Cievert Ltd has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Cievert Ltd has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our business

Cievert is a UK based company that specialises in digital health and healthcare delivery.  Cievert’s main areas of operations include oncology, pathology and physiotherapy.  Cievert has 86 registered suppliers.

Our high risk areas

We understand that our biggest exposure to Modern Slavery is in our supply chains.  Within these areas, new suppliers are subject to due diligence checks in the form of ethical/compliance audits conducted by or on behalf of Cievert.  Such audits are, amongst other things, intended to identify any Modern Slavery practices.  If issues are identified, appropriate investigative and remedial actions will be taken.

Our policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

  • Anti-slavery policy. This policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help.
  • Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
  • Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
  • Code of business conduct. This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.

Our suppliers

Cievert Ltd conducts due diligence on all suppliers.  This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery [and on site audits which include a review of working conditions].  Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.

In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:

  • They have taken steps to eradicate modern slavery within their business
  • They hold their own suppliers to account over modern slavery
  • (For UK based suppliers) They pay their employees at least the national minimum wage / national living wage (as appropriate)
  • (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations
  • We may terminate the contract at any time should any instances of modern slavery come to light]

Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

  • No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.]

Approval for this statement

This statement was approved by the Board of Directors on 18th June 2018

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