Corporate Social Responsibility

Modern Slavery is a term used to encompass slavery, servitude, forced or compulsory labour and human trafficking. Modern Slavery is a crime and a violation of human rights. This statement extends to all our offices within DOCOsoft.

This Modern Slavery and Human Trafficking statement is made pursuant to section 54 of the UK Modern Slavery Act 2015 (the “Act”). It sets out DOCOsoft’s approach, governance and actions to combat Modern Slavery in its various forms. 

Commitment 

DOCOsoft is committed to upholding its responsibilities to our people, those we come into contact with, the communities in which we work and the environment. We maintain a high standard of business ethics. We respect and support the protection of human rights in all our business units irrespective of domicile or place of operation.

This commitment requires us to assess human rights risks in all our businesses and resulting from our operations, considering equality, corruption and bribery, child labour, forced labour, slavery and trafficking, non-discrimination, health and safety and working conditions. 

Governance 

The Chief Executive is responsible for the overall strategy and business model. They set the tone from the top for how we do business. The Senior Leadership Team, along with the CEO is responsible for the day to day running of the business and draws its members from core areas of management.

DOCOsoft’s risk management framework and processes are designed to identify, evaluate and manage the risk of the Company not achieving its business objectives or incurring losses. The key aspects of the Company’s control activity in relation our various legal, regulatory and policy-related obligations are as follows: 

  • Policies that apply to our operations and our people, outlining the standards and specific behaviours that we expect;
  • Communication and training on our policies, on specific areas of risk, and our obligations as legally required;
  • Risk assessment to understand our exposures and to assess our controls;
  • Reporting of our control activity and any issues to the relevant governance forums; and
  • Whistleblowing procedures to ensure that all staff can highlight failures to meet policies or regulations.

The application of each of the above areas of control activity to the area of Modern Slavery and Human Trafficking is outlined below.

Our Policies relating to Modern Slavery and Human Trafficking 

DOCOsoft has a comprehensive set of polices which apply to all colleagues irrespective of where they are based or deployed. We review our policies on a regular basis (at least annually) to ensure that they remain fit for purpose. Our policies relate to the Company’s relationships with our staff and those who come into contact with us; they support the promotion and maintenance of a consistently high standard of business ethics. We believe that high standards of business ethics and a consistency of approach can add value to our operations and further enhance our reputation. Here we have set out our approach, reflecting our attitudes, adopted processes and our progress in maintaining an ethical and responsible business. 

The policies and other documents that are relevant to our ongoing efforts to avoid Modern Slavery and Human Trafficking within our operations are as follows:

  • Our Corporate Values – these set the overall tone for what is expected of DOCOsoft colleagues and our operations.
  • Equal Opportunities – outlines measures to ensure that colleagues are treated fairly and without discrimination. 
  • Health and Safety –communicates how we manage the safety and wellbeing of our people and those that come into contact with us.
  • Privacy and Data Protection – describes our approach to protecting the data we hold, including our own data and information that is entrusted to us by others. 

Communications and Training 

DOCOsoft utilises several conduits to ensure that our standards and policies are communicated to – and understood by – our people. Policies are communicated to colleagues on joining, with acknowledgement of being read and understood required as a key part of the induction programme. Mandatory training takes place annually for certain areas. This is monitored across the Company and compliance reported to the management team. There is ongoing communication via e-mail and regular briefings and seminars for the relevant people on specific topics. Our policies and procedures are available on our DOCOsoft intranet, to all colleagues and are communicated proactively as appropriate (for example, when they are updated) to all staff by e-mail. 

Risk Assessment 

Overall: we continually assess our exposure, and the potential for exposure, to risks and have a control and reporting framework to communicate issues. This includes an assessment of the risk of our operations utilising or being complicit in slavery and trafficking activities. We have assessed that this risk is low. As a of provider of professional and technical services, we are not a direct manufacturer or supplier of goods. Our staff generally have a high level of technical capability and professional qualification.

Risk assessment of our Supply Chain: our supply chain does not have a need for a high degree of manufacturing or a labour-intensive resource. Our main exposure for potential slavery and trafficking risks exists through the maintenance and support of our IT infrastructure. Our risk assessments show a low level of risk within our IT procurement, through the use of and relationships with major vendors who have committed to similar levels of adherence to the Act as our own. For certain services or projects, which have a potential for additional exposure, a specific and full risk assessment would be carried out.

Reporting 

Several functions within DOCOsoft have a direct role in compliance with the law, regulation and our own standards. These include our Finance teams, Internal Audit, and Human Resources. Individual teams within our client facing businesses are also responsible for ensuring compliance by working within our standards. Each of these teams are responsible for making risk assessments and reporting any exposure or incidents of non-compliance, including in relation to our Modern Slavery and Human Trafficking obligations. No issues of non-compliance with our Modern Slavery and Human Trafficking obligations have been reported in previous years.

Whistleblowing 

DOCOsoft encourages members of staff to maintain high standards of behaviour and to report any wrongdoing that falls short of this fundamental principle. Our Whistleblowing Policy aims to ensure that any member of staff who raises concerns in good faith can do so on a confidential basis without fear of reprisal or victimisation, and in the knowledge that their concerns will be taken seriously and investigated appropriately. The Policy applies to all colleagues acting in any capacity within the company.  

No issues of non-compliance with our Modern Slavery and Human Trafficking obligations were reported via our Whistleblowing Procedures in previous years.

Next Steps 

Whilst we believe our exposure to risks relating to Modern Slavery and Human Trafficking are low, we recognise that all businesses have a duty to ensure that this topic receives continual and appropriate attention and that we remain diligent in our efforts to reduce slavery and trafficking in all its forms. We shall continue to assess our risks both internally and through interaction with our partners, both current and future. 

Specific actions that are proposed over the next year are as follows: 

  • To continue to educate our management teams and staff to ensure that our controls and risk assessments meet the challenge of our high standards.
  • To further develop the verification of the risks posed by our supply chain.
  • To ensure our policies and training programmes remain appropriate.

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