This statement sets out Civica'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.
Civica Group Limited, including its associated and subsidiary companies, recognises that it has a responsibility under the Modern Slavery Act 2015 to take a robust approach to slavery and human trafficking and we are absolutely committed to preventing slavery and human trafficking in our corporate activities, and to ensuring that our supply chains are free from slavery and human trafficking.
Organisational Structure and Supply Chains
We are a global leader in software for public services, providing the cloud software and digital solutions used by more than two million professionals. Headquartered in London, we have facilities based around the UK. We also have operations and offices in Ireland, Australia, New Zealand, Singapore, India and the USA. Our supply chains are predominantly based within the countries in which we operate. Our parent organisation is Civica Group Ltd
Due the nature of our services, our business operations are predominantly in the Software Development and Technical arena, in addition to professional services including project management, customer support, service delivery and implementation.
We provide services to a range of public and public sector organisations, such as local and national government, NHS and private hospitals, emergency services and libraries.
Civica has a complex supply chain due to the variety of solutions and product sets offered to our customers. This supply chain can be split between four key areas: Property, Indirects, ICTservices and ICT Hardware. Civica focuses primarily on key market leaders in its market such as Microsoft/Amazon Web Services / HP & Cisco where downstream supply chains are adequately vetted and reported upon. An annual Modern Slavery audit is completed as part of our ongoing assurance due diligence (this complements our new supplier on-boarding process), to ensure the supply chain is compliant with risks such as product, location, country of origin and evidence of company policy monitored.
We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:
- HR Policy - We promote our Modern Slavery Policy within our Team Handbook which is available to all colleagues and is provided upon commencement of employment. We have zero tolerance of any threat of physical or sexual violence, harassment or intimidation against employees and their family, or close associates. Our policies are clearly defined and communicated to all employees. All our employees are treated fairly and equally, and are paid at least the national minimum wage. Our employees won’t be forced to work in excess of the number of hours permitted in law, and normal working hours won’t exceed 48 hours per week average unless the employee agrees.
- Purchasing Policy - The organisation is committed to conducting purchasing activities in a fair, objective and transparent manner that satisfies the requirements of accountability and internal controls including but not limited to Civica’s ‘Quality Management’, ‘Environmental’, ‘Ethical Code of practice’, ‘Anti-Bribery’ and ‘Modern slavery and Human Trafficking’ policies which fulfil legal and financial obligations and effectively manages commercial risk. Emphasis is placed on selecting suppliers and service providers that demonstrate recognisable environmental, sustainable, business integrity along with Corporate Social Responsible (CSR) standards including but not limited to compliance with laws and regulations, respect for human rights, labour working conditions, equal opportunities, health and safety accreditation, maintenance and promotion of information security, fair trade and acceptable corporate ethics.
- Recruitment Policy - The organisation uses only specified, reputable employment agencies to source agency workers and always verifies the practices of any new agency it is using before accepting workers from that agency.
- Whistleblowing Policy - We encourage all of our employees, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, Civica. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation.
- Our values - Civica’s values of Knowledge, Integrity and Action makes clear to our employees the actions and behaviour expected of them when representing Civica. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.
We undertake due diligence in relation to slavery and human trafficking when considering taking on new suppliers, and review our existing suppliers on a periodic basis. Our 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 which have a greater degree of focus on slavery and human trafficking where general risks are identified
- When a supplier is deemed to be higher risk by country of origin and/or lack of suitable policy/processes, an investigation is raised and assessed by senior members of the purchasing team which can result in the vendor being inactivated.
- 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
Action taken to address Modern Slavery
Due to the nature of the supply chain, Modern Slavery risks are inherently higher in the hardware and peripheral item category, as the production process relies on factory labour.
Additional steps to manage the risk include sourcing goods from recognisable brands and reputable resellers, with evidenced processes and policies in place along with products/ suppliers that are assessed based on the country of origin. Countries and regions are assessed for risk based on the Global Slavery Index, taking into consideration the latest updates from The Department for International Trade.
The organisation has raised awareness of modern slavery issues by circulating information to employees.
The information explained to relevant employees:
- The principles of the Modern Slavery Act 2015 and how it applies to Civica;
- How employers can identify and prevent slavery and human trafficking;
- What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
- What external help is available, for example through the Modern Slavery Helpline.
We are currently improving our colleague mandatory training and planning to strengthen knowledge through these activities.
March 2021 Update
This is the fifth year of reporting on modern slavery from the Civica Group. We continue to ensure that the working conditions for all of our employees exceed statutory requirements in all of the countries that we operate in, and we conduct regular reviews against market standards. With over 5,000 employees across the globe, we continue to be an employer of choice across all our regions.
We have received reaccreditation as an Investors in People Gold business as well as Employer of Choice in the Australian Business Awards for the third year running. We continue to partner with leading associations including techUK, the Tech Talent Charter, Specialisterne NI, as well as being a signatory to the Armed Forces Covenant. We continue to apply these high standards across the Group, and in 2021 we are seeking to improve and build on our standing as an Employer of Choice.
In 2020, we adapted many employee programmes to meet the needs of remote working during COVID-19. We launched a range of new engagement initiatives: through our internal YourVoice programme, we maintained an excellent employee Net Promoter Score of +50, up 18 points on the previous year. Regular Pulse surveys during 2020 helped us understand the needs of our employees during the pandemic. This helped us continually adapt our strategy, proactively meet everyone’s needs and support their ongoing health and wellbeing.
We also continue to review our Group policies and practices around diversity and inclusivity (D&I) and are listed as a Financial Times Diversity leader in 2021 for the second year running. We have taken further steps to improve D&I, raising awareness of the challenges people may face while ensuring we foster a culture of inclusivity and belonging. We include D&I modules on all leadership programmes and we rolled out a D&I awareness webinar with great attendance and feedback across the Group.
We have improved our whistleblowing policy, ensuring that there is an anonymous process for employees, customers and other business partners to report their concerns related to the direct activities, or the supply chains of Civica. Our whistleblowing procedure continues to be designed to make it easy for employees to make disclosures without fear of retaliation.
Due to the nature of the business, we have not identified any high-risk Modern Slavery concerns in 2021.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Civica’s slavery and human trafficking statement for the financial year ended 30.09.2021.
As a leading global business, Civica recognises that modern slavery and human trafficking are significant global issues that present challenges for businesses around the world. In line with our values of Knowledge, Integrity and Action, we are committed to continually improving our practices to combat modern slavery and human trafficking within our supply chains. We have a zero-tolerance approach to these issues and act with integrity in all our business arrangements."
Wayne Story, CEO