MODERN ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY STATEMENT

Insurance Data Solutions – Modern Slavery & Human Trafficking Statement

(FY 2024/25)

We are not required to publish a statement under Section 54 of the Modern Slavery Act 2015. We choose to publish voluntarily and proportionately. This statement sets out the practical steps Insurance Data Solutions (“IDS”, “we”, “our”) takes to help prevent modern slavery and human trafficking in our business and supply chains.

Our business and supply chains

IDS provides data services and IT solutions to the insurance sector. Our operations are UK-based. Our supply chain primarily comprises professional services, software, data, and cloud platforms. At the time of publication, we assess our risk as low and do not engage high-risk suppliers. We will reassess this annually.

Roles and responsibilities

Policy & oversight: Company directors set and review our approach and policies.
Risk & due diligence: Directors oversee proportionate risk assessments in recruitment and supplier onboarding.
Reporting: All staff members are expected to report any concerns so that they can be addressed promptly.

Policies and standards

We use a short set of policies and controls to guide behaviour and manage risk:

Modern Slavery & Human Trafficking Policy (applies to everyone working for us).
Anti-Slavery and Human Trafficking Policy (complements and reinforces the above).
Employee Code of Conduct (expected behaviours when representing IDS).
Anti-Bribery & Corruption Policy (separate standalone policy).
Supplier Relationship Policy (includes modern-slavery expectations for suppliers).
Integrated Management System (IMS) aligned with ISO/IEC 27001 (information security) and ISO 9001 (quality), supporting governance, supplier management, and continual improvement.
Contracts & annual reviews (annual check of relevant policies and key suppliers).

Due diligence (people and procurement)

Recruitment: Right-to-work checks; reputable agencies only; no worker-paid recruitment fees.
Supplier onboarding: Risk screening; acceptance of our Supplier Relationship Policy (or equivalent standards); inclusion of a modern-slavery clause in new contracts.
Monitoring: Given our low-risk profile, we use proportionate annual checks and will escalate if our risk changes.
Remediation: If we identify harm, we will collaborate with the relevant authorities and affected parties to facilitate remediation.

Training and culture

Modern slavery awareness is included in induction and annual refresher training for all staff; managers and anyone who buys services receive simple role-specific guidance. Completion is tracked.

Pay, conditions, and speaking up

All UK employees are paid at or above the applicable UK National Minimum Wage / National Living Wage. We operate an open-door approach and a Grievance Policy so concerns about pay or conditions can be raised and addressed quickly.

Reporting concerns (inside and outside IDS)

Employees are encouraged to raise concerns with their line manager or HR. We do not operate a separate confidential whistleblowing hotline. Where appropriate, concerns may also be reported externally to the Modern Slavery & Exploitation Helpline or the police (999 in an emergency).

Data protection and records

We process and retain any personal data related to this policy in line with UK data protection law and our HR & Employee Privacy Notice.

Measuring effectiveness (KPIs)

To keep things proportionate, we track a small set of measures and review them annually:

Training completion: 100% of staff complete annual modern-slavery training (new starters within 30 days).
Supplier coverage: 100% of our top suppliers (by annual spend) either have an Anti-Slavery Policy, accept our Supplier Relationship Policy provisions, or complete a short modern-slavery questionnaire as part of our annual due diligence reviews.
Contract clauses: 100% of new supplier contracts include a modern-slavery clause.
Incident handling: If any concerns arise, triage within 2 business days and agree on a remediation plan within 30 days.