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Slavery and Human Trafficking Statement

Introduction

This statement sets out Ideagen'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 the financial year, 1 April 2018 to 31 March 2019.

The Company recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The Company 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, Business and Supply Chain

Ideagen is a UK-headquartered, global technology company quoted on the London Stock Exchange AIM market (Ticker: IDEA.L).

The Group provides software and services to organisations operating within highly regulated industries such as aviation, banking and finance and life science, healthcare and manufacturing with its main operational premises spread throughout the UK, EU, US, Middle East and SE Asia.

With a portfolio of software products including Q-Pulse, Coruson, Pentana Audit, Pentana Performance and PleaseReview, Ideagen helps its clients reduce costs, improve operational efficiency, strengthen compliance and oversight, and anticipate and manage every detail of risk.

Currently, more than 3,700 organisations use Ideagen's products including 7 of the top 10 UK accounting firms, all of the top aerospace and defence companies, and 75% of the world's leading pharmaceutical firms.

Ideagen's diverse and varied customer base includes many well-known, global brands such as British Airways, Aggreko, BAE, Ryanair, US Navy, KLM, BBVA, Bank of New York, Commerzbank, Meggitt, Heineken, Johnson Matthey, Haeco Group and European Central Bank. As well as this, Ideagen counts 180 hospitals across the UK and US amongst its client base.

Ideagen directly employs ~500 members of staff across its global operations.

We are serious about our brand because it’s part of our identity and so is our commitment to corporate social responsibility. We believe transparency is the best way we can ensure the public that we are doing our best as an ethical corporate citizen. In that spirit, we have published our annual statement for slavery and human trafficking, made in compliance with section 54 of the Modern Slavery Act 2015, in which we explain how slavery and human trafficking can affect our business and the steps we are taking to ensure we prohibit it.

This past financial year ending 31 March 2019, we took the following key steps to ensure slavery and human trafficking did not occur within our Company or supply chain.

Slavery and Human Trafficking Policies

Notably, we developed our Slavery and Human Trafficking Policy, which can be found on Coruson. We also updated our Supplier Management Policy, which can also be found on Coruson.

Relevant Policies

The Company 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:

  • Whistleblowing Policy: The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of
  • General Rules and Code of Conduct: The Company's code makes clear to employees the actions and behaviour expected of them when representing the Company. The Company strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply
  • Supplier’s Policy and Procedure: The Company 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 The Company 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 Company's supplier code of conduct will lead to the termination of the business relationship.
  • Recruitment Policy: The Company 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. No labour provided to the Company in the pursuance of the provision of its own services is obtained by means of slavery or human Ideagen strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom, Dubai, Bulgaria, United States, and Malaysia as appropriate, and in many cases exceeds those minimums in relation to its employees.
  • Remuneration and Benefits Policy: Ideagen employees are offered a competitive remuneration package and provides a comprehensive range of benefits to its employees. Ideagen regularly conduct employee engagement surveys on an anonymous basis to give employees a voice on their individual employment, their department and the Company, as
  • Grievance Policy: Our Respect at Work, Grievance and Voicing your Concerns for Staff policies additionally give a platform for our employees to raise concerns about poor working
  • Anti-Bribery and Corruption Policy: The Company is committed to the highest standards of ethical conduct and integrity in its business activities in the UK and overseas. The Company will not tolerate any form of bribery by, or of, its employees, customers, suppliers or consultants or any person or body acting on its

Due Diligence Procedures

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

  • Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
  • Evaluating the modern slavery and human trafficking risks of each new supplier;
  • Conducting supplier audits or assessments through the Company's own staff which have a greater degree of focus on slavery and human trafficking where general risks are identified;
  • Taking steps to improve substandard suppliers' practices, including providing advice to suppliers and requiring them to implement action plans;
  • 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; and
  • Advising our new and existing suppliers of our commitment to combatting modern slavery within our organisation and our similar expectation from our suppliers to us. This entails sending out a Modern Slavery Act Declaration, for new and existing suppliers to sign to confirm that they will uphold the principles of the Act and provide all services and/or goods free from slavery and human

Next Steps

We recognise and understand the importance of the Modern Slavery Act and are committed to reviewing and assessing the risks in our supply chain. Over the course of the coming financial year, we will continue to review our supplier contracts and procurement processes to ensure continued compliance with the Modern Slavery Act.

Approval

This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ended 31 March 2018. This statement was approved by our Board of Directors on 5th November 2018 and signed on its behalf by Ben Dorks, Chief Executive Officer.

Ben Dorks, Chief Executive Officer

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