Anti-Slavery and Human Trafficking Policy

1. Policy Statement

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OutSmart Services ("OutSmart," "we," "us," or "our") is committed to conducting business ethically and with integrity. We have a zero-tolerance approach to modern slavery and human trafficking in all its forms, and we are committed to acting ethically and with integrity in all our business dealings and relationships to ensure that modern slavery is not taking place anywhere in our own business or in any of our supply chains.

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This policy applies to all individuals working for OutSmart or on our behalf in any capacity, including employees, directors, officers, agency workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and suppliers.

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2. Organisational Structure and Business

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OutSmart Services is a provider of business process outsourcing services, specialising in healthcare administration support. Our operations are based in the UK and the Philippines. We work with a range of clients and suppliers, primarily in the  healthcare sector.

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3. Definitions

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• Modern Slavery: Encompasses slavery, servitude, human trafficking, and forced labor. Victims are exploited by others for personal or commercial gain.

  • Slavery: Ownership over a person.

  • Servitude: Obligation to provide service that is imposed by coercion.

  • Human Trafficking: Arranging or facilitating the travel of another person with a view to exploitation.

  • Forced Labor: Work or service exacted from any person under the menace of a penalty and for which the person has not offered himself or herself voluntarily.

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4. Our Commitment

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We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business or our supply chains. This commitment is underpinned by the following principles:

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• We will conduct our business ethically and with integrity.

• We will not tolerate modern slavery or human trafficking in any form.

• We will take steps to identify and assess the risks of modern slavery in our business and supply chains.

• We will implement and enforce effective systems and controls to ensure modern slavery is not taking place.

• We will provide training to our staff to ensure they understand the risks of modern slavery and how to identify and report them.

• We will encourage the reporting of any concerns and protect whistleblowers.

• We will monitor the effectiveness of our efforts to prevent modern slavery and human trafficking and will review and improve our policies and procedures as necessary.

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5. Risk Assessment

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OutSmart will undertake a risk assessment to identify and evaluate the potential risks of modern slavery within its business and supply chains. This assessment will consider factors such as:

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• The countries and sectors in which we operate.

• The nature of our supply chains.

• The types of services we provide.

• The vulnerability of workers in our supply chains.

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The results of this risk assessment will be used to inform the development and implementation of appropriate policies, procedures, and controls.

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6. Due Diligence

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OutSmart will exercise due diligence when dealing with suppliers and other business partners to ensure that they adhere to the same high standards as we do and that they are taking steps to prevent modern slavery in their own businesses and supply chains. This may include:

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• Conducting supplier audits and assessments.

• Including anti-slavery clauses in our contracts.

• Requiring suppliers to provide evidence of their compliance with anti-slavery laws.

• Verifying the labor practices of our suppliers.

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7. Reporting Concerns

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OutSmart encourages all individuals working for the Company or on its behalf to report any concerns they may have about potential instances of modern slavery or human trafficking. A Whistleblowing Policy is in place to provide a safe and confidential mechanism for reporting such concerns.

We will ensure that individuals who raise concerns in good faith are protected from any retaliation.

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8. Training

OutSmart will provide training to relevant employees to ensure that they are aware of:

• The Modern Slavery Act 2015 and other relevant legislation.

• The risks of modern slavery and human trafficking.

• How to identify potential instances of modern slavery.

• The procedures for reporting concerns.

• Our Anti-Slavery and Human Trafficking Policy.

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9. Monitoring and Review

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OutSmart will regularly monitor and review the effectiveness of this policy and the steps we have taken to ensure that modern slavery and human trafficking are not taking place in any part of our business or our supply chains.

This policy will be reviewed and updated as necessary to reflect changes in legislation, best practices, and our business operations.

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10. Responsibility

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The HR Department has overall responsibility for ensuring that this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

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HR Head has day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery and human trafficking.

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11. Communication

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This policy will be communicated to all employees, suppliers, and other relevant business partners. It will also be made available on our website.

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This policy is in addition to any other relevant policies we have.