Purpose
1.1 OneTouch Health is committed to acting ethically, with integrity, and to preventing modern slavery and human trafficking in our own business and throughout our supply chains.
This policy sets out our commitment to identifying and mitigating the risk of modern slavery, and the standards we expect of our employees, workers, suppliers and other business partners. It applies across all of OneTouch’s operations in Ireland, the United Kingdom and Australia.
Scope
2.1 This policy has been developed with reference to the UK Modern Slavery Act 2015( UK) and the Australian Modern Slavery Act 2018 (Cth).
Responsibility
3.1 The Board of OneTouch Health has overall responsibility for ensuring this policy complies with our legal and ethical obligations.
3.2 The Chief Operating Officer is the day-to-day policy owner and is responsible for its implementation, for monitoring its effectiveness, and for reviewing it annually or sooner if required by changes in law or in our business.
3.3 All managers are responsible for ensuring this policy is understood and followed by those they manage, including contractors and temporary workers.
3.4 Employees, workers, customers and suppliers are encouraged to report any concerns about modern slavery or human trafficking connected to OneTouch’s business or supply chains as soon as possible. Concerns can be raised with a line manager, Group HR Director, Chief Operating Officer or in line with OneTouch’s Whistleblowing Policy, which allows concerns to be raised confidentially and without fear of victimisation or reprisal. All reports will be taken seriously and investigated appropriately.
3.5 OneTouch provides training and guidance to employees involved in recruitment, procurement and supplier management, to help them recognise the signs of modern slavery and understand how to escalate concerns. This policy is made available to all employees on induction and is available on request to customers, suppliers and members of the public.
Definitions
Modern slavery is an umbrella term covering:
- Slavery – where ownership is exercised over a person;
- Servitude – the obligation to provide services, imposed by coercion;
- Forced or compulsory labour – work or services extracted from any person under the menace of penalty, for which the person has not offered themselves voluntarily; and
- Human trafficking – arranging or facilitating the travel of another person with a view to exploiting them.
These practices can affect anyone, but certain groups – including migrant workers, agency and seasonal staff, and people recruited through third-party labour providers – can be at greater risk of exploitation.
Procedure
5.1 Our Supply Chain Structure
OneTouch provides SaaS-based care management software to home care and social care providers, employing approximately 150 people across Ireland, the UK and Australia. As a technology business, our own direct supply chain risk profile is relatively low and centres mainly on:
- Cloud infrastructure, hosting and software vendors;
- Professional services (legal, audit, consultancy and outsourced technology development); and
- Office facilities, cleaning and premises-related services, and recruitment and staffing agencies.
We recognise that facilities services, subcontracted development work and third-party recruitment can carry a higher relative risk of exploitative practices than our core technology supply chain, and we focus our due diligence accordingly.
5.3 Recruitment and Employment Practices
OneTouch is committed to fair recruitment and employment practices across all jurisdictions in which we operate. In particular, we ensure that:
- No worker is required to pay recruitment fees to secure employment with us;
- All workers are free to leave their employment on giving reasonable notice, and are not subject to the retention of identity documents or other means of coercion;
- All employees are paid at least the applicable national minimum or living wage, and receive clear, written terms of employment; and
- Employment contracts and working arrangements comply with local employment law in Ireland, the UK and Australia.
5.4 Review and Update
We regularly review and update this statement to ensure its continued relevance and effectiveness.