KashFlow – Slavery and Human Trafficking Statement

Introduction

This statement sets out IRIS Software Group’s (Organisation) 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. This statement relates to actions and activities during the financial year 1 May 2016 to 30 April 2017.

Organisational structure and supply chains

This statement covers the activities of IRIS Software Group Limited and its subsidiary companies (as defined under the Companies Act 2006):

The Organisation is a leading provider of business critical software and services in the UK. It connects accountants, businesses and their employees enabling them to efficiently manage their financial, compliance and human capital resource requirements to achieve success. The Organisation offers a broad range of specialist accountancy, financial management, human resource management and payroll solutions – delivered as a choice of integrated on premise software and cloud-based applications – managed under the leading IRIS, PTP, KashFlow, Keytime, Cascade, PS Financials and Earnie product brands.
The Organisation’s contractors and suppliers are primarily based within the UK and EU
Products, Services and software development are generally provided in-house by the Organisation rather than in a supply-chain method.

Countries of operation and supply

The Organisation currently operates in the following countries:

United Kingdom – majority of business conducted within the United Kingdom
India – 2-3% of total group revenues, entity located in India is a subsidiary of the Organisation, which provides business process outsourcing services for Organisation clients based primarily in the United Kingdom.

Third party Organisations within the supplier/contractor pool and other companies that may be engaged with are expected to ensure their goods, materials and labour-related supply chains:

Fully comply with the Modern Slavery Act 2015; and are
Transparent, accountable and auditable; and are
Free from ethical ambiguities.

Relevant policies

The Organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

IRIS Anti-Slavery Policy: Described in more detail below under ‘Awareness Raising Programme’.
Whistleblowing Policy: The Organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the Organisation. The Organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
Employee code of conduct: The Organisation’s code makes clear to employees the actions and behaviour expected of them when representing the Organisation.
The Organisation uses only specified, reputable employment agencies to source labour and verifies the practices of any new agency it is using before accepting workers from that agency.

Risk Assessment

The Organisation has reviewed material suppliers and assessed whether any particular risks of slavery or human trafficking arise. It does not consider that key relationships with professional or business services suppliers give rise to material risks in this area. Risk may have the potential to arise in relation to internal facilities management, catering, and the supply of office electronic equipment. Risk is managed through the use of suppliers whom are considered to be reputable, and it has been specifically requested that all material regular suppliers confirm that their own business activities do not involve slavery or human trafficking.

Steps taken by the Organisation since May 2016 – Year 1

(A) Management responsibility and general awareness

Agreed management responsibility for this statement and the IRIS Anti-Slavery Policy and received unanimous endorsement from the Board.
Raised general organisational awareness.

(B) Risk assessment

Undertaken assessments using legal, risk and procurement teams to determine risk exposure.
Included the Modern Slavery Act 2015 within our statutory and regulatory compliance risk register to ensure the risk continues to be flagged, assessed and appropriately addressed.

In regards to relevant new contracts, the Organisation seeks to impose provisions for termination in the event of a modern slavery or human trafficking compliance breach by the supplier.

Steps to take – Year 2

(A) Management responsibility and general awareness

Report progress to the executive management team and the Board.
Raise awareness of this published statement by notifying organisations who are regularly engaged with.
Prepare the second annual statement.

(B) Risk assessment

Commence a review exercise of this policy against Organisation activities to establish whether the approach taken follows emerging best practice by:
Assessing and interpreting any recent or emerging case law and best practice;
Benchmarking activities against statements and action plans undertaken by similar organisations; and
Re-evaluating the risk of non-compliance as part of the cyclical compliance risk register assessment.

Act promptly where a compliance breach has been identified or flagged.
Continue to feed-back lessons learnt into the compliance risk management process.

Awareness-raising programme

As well as training staff, the Organisation has raised awareness of modern slavery issues by producing an IRIS Anti-Slavery Policy that is introduced to staff as part of the induction process and made available on the Organisation intranet thereafter.

The IRIS Anti-Slavery Policy explains to staff:

the basic principles of the Modern Slavery Act 2015;
how employees can identify and prevent slavery and human trafficking; and
what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the Organisation.

Board approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Organisation’s statement for the financial year ending 30 April 2017.

This statement has been approved by IRIS Software Group Limited’s board of directors, who will review and update it annually.

IRIS Software Group

Date: 30 April 2017