CARE CASCADES LTD

Modern Slavery and Human Trafficking Policy Statement

Document title

Modern Slavery and Human Trafficking Policy Statement

Organisation

Care Cascades Ltd

Company number

15163147

Registered office

16 Home Close, Oxford, OX2 8PS

Version

1.0

Effective date

15/07/2024

Approved by

Tom Stocker, Company Director, on behalf of the Board

Review cycle

Annual, or sooner on material change

Next review due

15/07/2027

1. Purpose and scope

Care Cascades Ltd (“the Company”) is committed to acting ethically and with integrity in all its business dealings and relationships. This policy sets out the Company’s commitment to preventing modern slavery and human trafficking in its own operations and across its supply chains, and the steps it takes to identify and mitigate that risk.

This policy applies to all persons working for or on behalf of the Company in any capacity, including directors, employees, contractors, consultants, associates, and suppliers.

Note on legal basis: Section 54 of the Modern Slavery Act 2015 requires a slavery and human trafficking statement only from commercial organisations with an annual turnover of £36 million or more. The Company falls below this threshold and so is not under a statutory duty to publish such a statement. This policy is adopted voluntarily as a proportionate measure to meet UK public sector procurement expectations — including those arising under the Procurement Act 2023, Procurement Policy Note 02/23 (Tackling Modern Slavery in Government Supply Chains), and NHS supplier assurance processes — and to reflect the Company’s own values.

2. Policy statement

Modern slavery is a criminal offence and a violation of fundamental human rights. It encompasses slavery, servitude, forced and compulsory labour, and human trafficking, all of which deprive a person of their liberty in order to exploit them for personal or commercial gain. The Company has a zero-tolerance approach to modern slavery in all its forms.

Given the nature of the Company’s work — digital health consultancy and software services delivered predominantly within the UK — the inherent risk of modern slavery within its direct workforce is assessed as low. The Company nonetheless recognises that risk can arise indirectly through its supply chain, particularly in the procurement of hardware, electronics, and outsourced or offshore technical services, and it manages this risk accordingly.

3. Definitions

For the purposes of this policy, the following terms carry the meanings given in the Modern Slavery Act 2015:

• Slavery — the exercise of powers of ownership over a person.

• Servitude — an obligation to provide services imposed by coercion, with the victim unable to change their condition.

• Forced or compulsory labour — work or service exacted under the menace of a penalty and not offered voluntarily.

• Human trafficking — arranging or facilitating the travel of another person with a view to their exploitation.

4. Roles and responsibilities

Accountability for this policy rests with the Board. Responsibilities are allocated as follows:

Role

Responsibility

Board / Directors

Hold ultimate accountability for the policy, approve it annually, and ensure adequate resources are allocated to its implementation.

Designated lead

The Director responsible for compliance owns day-to-day implementation, due diligence on suppliers, training, and investigation of any concerns raised.

All staff and associates

Comply with the policy, complete required awareness training, apply due diligence in their work, and report any suspected modern slavery without delay.

Suppliers and subcontractors

Expected to adopt equivalent standards, respond to due-diligence enquiries, and cascade these expectations through their own supply chains.

5. Due diligence and risk management

The Company takes a proportionate, risk-based approach to due diligence. In practice this means:

1. Assessing supply chain risk according to sector, geography, and labour intensity, and focusing attention where risk is highest (for example, hardware manufacturing and offshore service provision).

2. Incorporating modern slavery clauses into supplier contracts where the Company is the contracting party, requiring suppliers to comply with applicable law and to permit reasonable verification.

3. Seeking confirmation, for material or higher-risk suppliers, that they have their own anti-slavery measures and, where applicable, a compliant Section 54 statement.

4. Cascading these expectations to subcontractors and associates engaged on Company work.

5. Maintaining records of due-diligence activity sufficient to respond to client and procurement assurance requests.

6. Recruitment and employment practices

The Company applies safe and transparent recruitment and engagement practices. It verifies the right to work of all staff and associates, pays at or above the statutory minimum, ensures no worker is charged fees to obtain work, and does not retain identity documents. Engagement is on the basis of clear, lawful terms freely agreed.

7. Training and awareness

All staff and associates are made aware of this policy at the point of engagement. Those involved in procurement or supplier management receive proportionate guidance on recognising the indicators of modern slavery — such as restricted freedom of movement, withheld wages, or signs of coercion — and on the steps to take if they have concerns.

8. Reporting concerns and whistleblowing

Anyone who suspects that modern slavery is occurring in any part of the Company’s operations or supply chain must report it to the designated lead at the earliest opportunity. Concerns may be raised in confidence and without fear of retaliation; the Company will not tolerate detriment to anyone who raises a genuine concern in good faith.

Where there is reason to believe a person is in immediate danger, the matter should be reported to the police on 999. Concerns may also be reported to the Modern Slavery and Exploitation Helpline on 08000 121 700.

9. Breaches of this policy

Any breach of this policy will be treated seriously. For employees and associates, a breach may result in disciplinary action up to and including termination of engagement. For suppliers, a breach may lead to termination of the commercial relationship. The Company will report suspected criminal conduct to the relevant authorities.

10. Governance, monitoring and review

This policy is owned by the Board and reviewed at least annually, or sooner where there is a material change in the Company’s operations, supply chain, or the applicable legal framework. The designated lead monitors implementation and reports to the Board on any concerns raised and actions taken.

11. Approval

This policy has been approved by the Board of Care Cascades Ltd and is published with the authority of the Directors.

Signed: Tom Stocker

Position: Director, for and on behalf of Care Cascades Ltd

Date: 23/07/2024