Modern slavery and human trafficking statement

Our Business

We ‘re a leading employee owned technology consultancy that works closely with a variety of sectors and in particular healthcare to drive positive change. We operate on a low hierarchy and flat structure, minimising the levels between our founders and employees.

With over 30 years experience of delivering projects with national, regional and local NHS partners, we have a long standing commitment to delivering positive healthcare outcomes. We also work closely with other government sectors, notably education.

We employ 253 specialist people specialising in Data Science and Engineering, IT Operations, Product Delivery and Business Analysis, Quality Assurance Testing, Software Development, Architecture and DevOps and User Centred Design. We operate in the UK and the USA from our offices based in Leeds and Manchester and our work is delivered by employees of Aire Innovate Limited as well as in conjunction with key partner organisations.

Our supply chains consist of the sourcing of:

• people for the provision of our services, including partner organisations
• IT equipment, including peripherals and office supplies

Definitions

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors and suppliers.Aire innovate Ltd strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.

‍Modern slavery and human trafficking

‍Modern slavery is a term used to encompass:

• slavery
• servitude
• forced and compulsory labour
• bonded and child labour
• human trafficking

Human trafficking is where a person facilitates the travel of another person with a view to that other person being exploited. Modern slavery is a crime and a violation of fundamental human rights.‍

Charges

sWe shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

1. We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
2. The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us, or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
3. We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
4. We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risk-based approach, we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct which sets out the minimum standards required to combat modern slavery and trafficking.
5. Consistent with our risk-based approach aspects of our supply chain that we believe are at risk of human trafficking and modern slavery are:
   5.1. Employment and recruitment agencies, and other third parties supplying workers to our organisation.
   5.2. Suppliers engaging workers through a third party.
   5.3. IT and office equipment suppliers.
6. Steps we have taken as an organisation to address these risks are:
   6.1. The requirement for all staff to read our Modern Slavery and Human Trafficking policy as part of their induction into the business;
   6.2. Publishing of our Modern Slavery Act Statement 2024 on Aire Innnovte’s intranet as well as webpage;
   6.3. Maintenance of The Good Business Charter Accreditation which commits Aire Logic to the ongoing adherence to the set of standards outlined in the Ethical Trading Initiative Base Code for Sourcing through a process of continuous due diligence.
   6.4. The requirement for all staff and third party workers to achieve Baseline Personnel Standard before engagement
   6.5. Selection of suppliers on the basis of transparent principles including agreed adherence to best practice and our code of conduct
7. As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our code of conduct.
8. If we find that other individuals or organisation’s working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.

Training and Awareness

‍All Aire Innovate employees, whether permanent or contracted, are provided with a comprehensive understanding of the concept of modern slavery upon induction to the organisation, this includes its forms, and its commonness amongst industries. We have anti-modern slavery policies and commitments, emphasising the company's zero-tolerance stance, and the importance of compliance. A series of policies and procedures are embedded to support all staff members with training and awareness around modern slavery, reporting a suspected incident, and the protection provided through our whistleblowing channels.

‍Monitoring and Reporting

‍Reporting procedures for employees who suspect or witness instances of modern slavery are in place, ensuring confidentiality and protection from retaliation.

‍Future Steps

‍At Aire Innovate, we are fully committed to continuous improvement within our operations. We recognise that there will be ways to improve our processes to combat human rights. This will include continuing to strengthen the due diligence process for supplier engagement and refining our risk assessment processes.