Modern Slavery Statement

Introduction

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 GovTech leader making software that delivers critical service to citizens around the world. We providecloud 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, Canada 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.

Due to the variety of solutions and product sets offered to our customers Civica has a complex supply chain which can be split into the key areas of Cost of Goods and Services (software, hardware, support, and professional service) and Indirect costs (Property, infrastructure and people related costs). Civica focuses primarily on key market leaders such as Microsoft, Amazon Web Services, HP and Cisco, where policies are published and in the public domain. This provides significant assurance across much of our supply chain that downstream supply chains are actively managed and meet compliance requirements. Annual Modern Slavery audits are completed as part of our supplier onboarding and ongoing assurance process.

Relevant Policies

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 - We are committed to conducting purchasing activities in a fair, objective, and transparent manner, with emphasis placed working with suppliers that demonstrate recognisable standards for corporate ethics, business integrity, human rights, working conditions, equal opportunities, health and safety and fair trade.
• 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 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.

Supplier due diligence is undertaken in relation to modern slavery and human trafficking when assessing new suppliers (onboarding),and reviewing existing suppliers (ongoing assurance) on a periodic basis. Our due diligence and reviews include:

• Mapping the supply chain broadly to assess particular product type 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 and 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.

Awareness-Raising Programme

The organisation has raised awareness of modern slavery issues by circulating information and training 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 operate an annual mandatory training program which includes information and awareness in connection with Modern Slavery risks and how to report any concerns through our internal processes.

December 2023 Update

Across the Civica Group, we continue to ensure that the working conditions for all our employees exceed statutory requirements in all the markets we operate in, and we conduct regular reviews against market standards. With over 6,000 employees across the globe, we continue to be an employer of choice across all our regions.

We’re proud to be an Investors in People Gold business, reaccredited in 2022. In 2023 we maintained our position as one of the top companies in the global Financial Times Diversity Leaders list, named as a top ten UK-based IT and software business. We were re-certified as a Great Place to Work in India 2023, for the third year running. Civica was also recognised in the Financial Times UK’s Leading Management Consultants for the Public and Social Sector. We are a disability confident employer and signatory of the Business Disability Forum.

In 2023, Civica was awarded the Armed Forces Covenant Employer Recognition Scheme (ERS) Silver Award to further cement our commitment to the Covenant and demonstrate that we go above and beyond to support those who serve, have served, or support serving family members in the Armed Forces.

Our ‘blended working’ model continues to place a greater emphasis on blended learning; we combine virtual and face-to-face training to offer a programme to suit everyone. While in-person learning is still vital for wider networking, we also make the most of technology for all-important collaboration and innovation.

We offer all our managers the tailored training needed to support remote/blended teams, inclusion, and maintain collaboration and innovative ways of working. This is backed by our focus on positive health, with access to support and advice, providing practical health and wellbeing support through programmes such as our Employee Assistance programme and wellbeing initiatives.

We also have 30 UK Mental Health Champions, with more waiting to complete their initial training and plans to expand the programme in India.

During 2023, we took further steps to improve inclusivity to ensure a supportive work environment for our diverse community, including launching our new Diversity, Equity and Inclusion (DEI) Training for all our leaders and a new DE&I eLearning programme for all employees.

We grew momentum in our global affinity groups: our LGBTQIA+ community attended Pride parades in Bristol, Belfast, and Vadodara, while our Menopause Group hosted a series of podcasts with journalist Kate Muir invited to talk. We also improved communications accessibility following feedback from our Accessibility Affinity Group, including the introduction of Alt text for all our images. In 2023 we celebrated South Asian Heritage Month and Black History Month by amplifying the voices and experiences of our colleagues, both internally and on our website & social media channels.

We recognise that work is crucial to a person’s dignity, well-being and development and we are committed to the creation of jobs and working conditions in which people can work in freedom, safety, and dignity at a global level. We expect the same from all contractors, suppliers, and other business partners across our global supply chain. We are committed to identifying and assessing any potential risks and eliminating the possibility of modern slavery and human trafficking occurring in our business.

We have a comprehensive whistleblowing policy, ensuring that there is a 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 anyone to make a disclosure without fear of retaliation. Due to the nature of the business, we have not identified any high-risk Modern Slavery concerns in 2023.

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 30.09.2023.