Introduction

This Modern Anti-Slavery and Human Trafficking Statement lays down our commitment to preventing slavery and human trafficking in our company activities, and the steps we have put in place with the aim of ensuring that there is no forced labor or human trafficking in our supply chains. We all have a duty to adhere to the Modern Slavery Act 2015 (the “Act”) to prevent such crimes against individuals and communities. Staff are expected to be alert and report their concerns and for management to act upon them.

Scope - organizational structure and supply chains

This statement covers all the business activities of Insurance Data Solutions as a provider of data services and IT solutions for the Insurance Sector. 
The following is the process by which the Company assesses whether particular activities or countries are high risk in relation to modern slavery or human trafficking:

Our ISO Risks-Based Approach to Mitigation

Our strategy is to identify and prevent potential modern slavery and human trafficking risks in our business activities and implement processes and controls to mitigate these.

Responsibility for the Company’s anti-slavery initiatives are as follows:

1 Policy: The company Directors are responsible for creating and reviewing policies. The process by which policies are developed includes understanding legal requirements and learning from best practices.

2 Risk Assessments: The Company Directors are responsible for risk assessments with respect to human rights and modern slavery in the recruitment process and supply chain.

3 Due Diligence and Reporting:  All employees are responsible for reporting known or suspected instances of modern slavery and human trafficking.

Culture & Training

It is a core value of our company to conduct our business with integrity and we expect everyone who works for us to act with the highest ethical standards.

To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company requires that all staff are made aware of the company’s Modern Slavery and Human Trafficking Policy and Procedure during their induction and when policies are reviewed annually.

Pay & Conditions

Our employees are all based in the UK and are paid at least the UK National Minimum Wage or Living Wage. We have a Grievance policy in place, annual performance reviews and encourage an "open door" policy to allow employees to voice any concerns about pay and conditions.

Supporting Policies, Contracts, and Procedures

The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.

The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations.

• Whistleblowing Policy - The Company encourages all its workers, customers, and other business partners to report any concerns related to its direct activities or its supply chains.
• Employee Code of Conduct - The Code of Conduct sets down the actions and behavior expected of employees when representing the Company as referred to in employee contracts.
• Corporate Social Responsibility (CSR) Policy - The Company’s CSR policy summarizes how we manage our environmental impacts and how we work responsibly with suppliers and local communities.
• Contracts & Annual Reviews - The Company annually audits its policies, agreements, and the performance of its employees and suppliers.

 Suppliers 

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers.  The process includes evaluating the modern slavery and human trafficking risks of each new supplier at the contract stage to determine whether the risks are high and whether we want to continue with the contract discussions and the relationship.

We review supplier performance annually and if any risks and concerns are raised, we will ask the supplier to complete a review. We will ask them to confirm how they are mitigating any risks associated with modern slavery and human trafficking. If we are not satisfied with their approach, we will consider terminating the business relationship.

Performance indicators

The Company uses the following key performance indicators to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains including the use of Due Diligence Supplier Questionnaires, Time Recording, and Payroll Systems.

Reporting any concerns

We reserve the right to take action against a supplier or an employee where we have concerns about nonadherence to the Act. We will report our concerns to the Modern Slavery Helpline and/or the police. In an emergency situation where we are concerned about the welfare of an individual, we will call 999. We encourage our employees to raise any concerns to the management / HR team in the first instance. Alternatively, our employees can follow the procedure in our Whistle Blowing policy to share any issues they have identified in the organization. We commit to investigating any concerns raised as soon as possible and will agree on a plan of action to address and mitigate any risks identified.

Record keeping

We may need to process or retain personal data about our employees in relation to this policy and we will process this data in accordance with the Data Protection Act, further information is provided in our HR Data Protection policy.

This Modern Slavery and Human Trafficking Statement will be annually reviewed as part of the company’s ISO 9001 and ISO 27001 Integrated information management system audits and updated as necessary.

The Managing Directors of IDS (New City Software Ltd.) endorse this policy statement and are fully committed to its implementation. Updated 19/09/2023