Modern Slavery Act Policy Statement

Introduction

This statement sets out Automedi Limited's (“The Company’s”) actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during this financial year.

As part of Information and Communication Technology, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of The Company:

• Software development
• Product Engineering
• Circuit Design, Development and Manufacturing
• All suppliers and manufacturers on behalf of The Company.

Countries of operation and supply

The organisation currently operates in the following countries:

• United Kingdom
• Estonia

The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

• Evaluate the policies and procedures of all suppliers procured for the development of products and services in the United Kingdom and abroad.
• Every organisation must provide The Company with proof of their compliance with the UK Modern Slavery Act. Failure to provide such statement renders any offer void.
• Any incident of slavery discovered by The Company, either directly or indirectly, through whatever such channel that applies, shall suspend the supplies until such time as a thorough investigation has been carried out.
• The Company may appoint a third-party investigator to conduct the investigation both internally and throughout the supply chain.

High-risk activities

The following activities are considered to be at high risk of slavery or human trafficking:

• Manufacturing operations in supply factories in China

Responsibility

Responsibility for the organisation's anti-slavery initiatives is as follows:

• Policies: All company policies are the responsibility of the board of directors. Mr Ethar Alali currently holds the post of
• Risk assessments: The Company
• Investigations/due diligence: Mr Ethar Alali will oversee the team responsible for any investigations and review any resulting evidence. The company has ultimate responsibility for the results of the investigation and will act to revoke contracts to suppliers with immediate effect.
• Training: To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to new staff during their induction. We also require our business partners to provide training to their staff and suppliers and providers, if not already undertaken.

Relevant policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations [select the relevant policies from the list below and include links to the full text]:

• Whistleblowing policy The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can complete our confidential disclosure form.
• Employee code of conduct The organisation's code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
• Supplier code of conduct The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of the organisation's supplier code of conduct will lead to the termination of the business relationship.
• Recruitment/Agency workers policy The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. [Describe the process by which risks of slavery and human trafficking are addressed in relation to agency workers, including examples (not necessarily named) of instances where action has been taken as a result of the risk of slavery and human trafficking.]
• Any other policies relevant to the organisation's business or sector We also refer to our corporate social responsibility policy.

Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation's due diligence and reviews include:

• evaluating the modern slavery and human trafficking risks of each new supplier;
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
• conducting supplier audits or assessments, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
• creating an annual risk profile for each supplier;
• taking steps to improve substandard suppliers' practices, including providing advice to suppliers through third party auditor and requiring them to implement action plans;
• participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular;
• After our turnover reaches £1 million, join the Ethical Trading Initiative, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
• invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Performance indicators

The organisation has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the organisation is:

• requiring staff working in China to have completed training on modern slavery by 5th April 2019;
• developing a system for supply chain verification expected to be in place by 5th April 2021, whereby the organisation evaluates potential suppliers before they enter the supply chain; and
• reviewing its existing supply chains is expected to be completed by 1st April 2018, whereby the organisation evaluates all existing suppliers.

Training

The organisation requires permanent staff working as HR professionals within the organisation to complete training on modern slavery.

The organisation requires permanent staff working as HR professionals to sign up to complete an online training course by 5th April of each financial year.

The organisation's modern slavery training covers:

• our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline;
• how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
• how to identify the signs of slavery and human trafficking;
• what initial steps should be taken if slavery or human trafficking is suspected;
• how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
• what external help is available, for example through the Modern Slavery Helpline, Gangmasters Licensing Authority and "Stronger together" initiative;
• what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
• what steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation's supply chains.

Awareness-raising programme

As well as training staff, the organisation has raised awareness of modern slavery issues by a reference to this document.

The comms explain to staff:

• the basic principles of the Modern Slavery Act 2015;
• how to identify and prevent slavery and human trafficking;
• what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
• what external help is available, for example through the Modern Slavery Helpline.

Board approval

This statement has been approved by the organisation's board of directors, who will review and update it annually.