Modern Slavery & Human Trafficking Statement
We are committed to working to ensure that there is no modern slavery or human trafficking in our supply chain or in any part of our business. This commitment is an integral part of our policies and our approach to human rights, which approach is informed by the UN Guiding Principles on Business and Human Rights.This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps and measures we have taken to seek to ensure that modern slavery and human trafficking does not occur in any part of our business operations or within our supply chain.
We operate a number of policies which reflect our commitment to acting ethically with regard to our employees, customers and all our business relationships, and they together address our approach to the identification and prevention of modern slavery and human trafficking:
• Modern Slavery Policy Statement is the standard we operate to in order to ensure that modern slavery and human trafficking does not occur in any part of our business or within our supply chain. As noted below, the policy statement is used for training purposes and is distributed to all senior managers and relevant staff within our business.
• Code of Conduct and Ethics Policy lays out the expectations and guiding principles for appropriate workplace behaviour.
• Public Interest Disclosure Policy details the procedures our employees should follow if they have any legitimate concerns about wrongdoing, unlawful conduct, acts of bribery, financial malpractice, dangers to the public or the environment, or possible fraud or other risks.
• Human Resourcing Policy outlines our approach to recruiting employees for all jurisdictions in which we operate. The principles of equality and diversity underpin all aspects of our resourcing activity, with recruitment and selection processes that are designed to ensure fairness, diversity and transparency.
• Anti-Bribery and Corruption Policy applies to all directors, officers and employees of the business, as well as third parties such as suppliers and sets out the rules we adopt with a view to preventing bribery and corruption in our business and supply chain.
Training and Awareness
We are committed to raising awareness of the policies listed above with all CMS Analytics employees. Senior management are briefed annually, which includes:Annual roll out of compulsory reading of key policies (listed above) which includes obtaining an attestation to confirm staff acknowledgement and adherence to each of these policies.Annual roll out of Compliance Computer Based Training for key regulatory matters including Anti Bribery and Corruption.Our senior managers also receive further support that includes training and line management guidance to ensure consistency of approach in terms of our recruitment processes, management of suppliers, fair treatment at work, and inclusion and diversity.
Our Supply Chain
We adopt a ‘zero tolerance’ to modern slavery and human trafficking, and we expect our supply chain to adhere to the same values. We ensure our suppliers have in place suitable anti-slavery and human trafficking policies and processes and verify any assurances given.We have carried out an initial assessment of our business and supply chain and consider that there is minimal risk of modern slavery or human trafficking. We have formed this view by adopting a risk-based approach in relation to our supply chain and conclude that it is not typically an industry with a high risk of modern slavery or human trafficking. We have, however, reviewed suppliers that operate within industries or countries that carry a higher degree of risk.
• In conducting appropriate due diligence, we assess our key suppliers across a number of key risk areas, at the onboarding stage and annually thereafter by way of an attestation ‘Compliance Supplier Attestation’, to identify where modern slavery and human trafficking risks may arise. Attestations are obtained from suppliers on a risk-based approach.
• Detailed financial analysis and assessment of their maturity, reputation and experience are also included. We may also seek to identify if our suppliers operate a vendor management programme and carry out due diligence on their own suppliers to ensure that appropriate standards are being passed through the supply chain.
• We seek assurances (where appropriate) from our suppliers that they are complying with all applicable laws and regulations which includes laws relating to minimum wages, working conditions, overtime, child labour and applicable labour and environmental laws. This allows us to select suppliers to work with us who adhere to the same high standards as we do.
• Our suppliers are required to notify us of a breach of any applicable laws or regulations. We also select a number of suppliers and monitor the content of modern slavery and human trafficking statements published by them.
Responsibility for ensuring that CMS Analytics has appropriate policies in place to identify and prevent modern slavery and human trafficking rests with the Board of Directors who have approved this statement.
Approved by Board of Directors, CMS Analytics
Andrea Brooks, CEO, 1st May 2019