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Anti-Slavery Policy

Introduction

InPhase recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

This statement sets out InPhase'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.

InPhase is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational Structure, Business and Supply Chain

InPhase is a privately-owned UK-headquartered, Decision Experience, Performance and BI software vendor.

InPhase provides software and services to organisations across the UK, EU, US and other territories.

InPhase specialises in the full process of improving performance through the provision of actionable information portals to staff at all levels of the business, so they can make better, fact-based decisions more quickly.

InPhase has notable expertise in Local Government, the NHS and other public services, with a substantial market share in these verticals.

InPhase is a company that represents social improvement and is passionate about its social responsibility. We have published our annual statement for slavery and human trafficking, made in compliance with section 54 of the Modern Slavery Act 2015, in which we explain how slavery and human trafficking can affect our business and the steps we are taking to ensure we prohibit it.

Our supply chains

Our main supply chains are:

  • Office consumables and equipment
  • Information Technology equipment and services
  • Estates goods and services
  • Business and Trading Services

Within these categories we believe the following types of goods and services contracts are likely to carry the highest risks in relation to modern slavery and human trafficking:

  • Cleaning
  • IT

These are typically purchased directly by InPhase.

Slavery and Human Trafficking Policies

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

InPhase’s purchasing policy has been updated and approved by the Executive Board and is communicated to key stakeholders on induction or on demand as applicable.  The updated policy reflects our commitment to act with integrity and ethically in all our business relationships and to implement and enforce effective systems and controls, including in relation to combatting modern slavery and human trafficking in our supply chains.

Relevant Policies

The Company operates the following policies:

  • Whistleblowing Policy: The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the Company.
  • This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of reprisal.
  • General Rules and Code of Conduct: The Company's code makes clear to employees the actions and behaviour expected of them when representing the Company. The Company strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply.
  • Supplier’s Policy and Procedure: The Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The Company works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of the Company's supplier code of conduct will lead to the termination of the business relationship.
  • Grievance Policy: Our Respect at Work, Grievance and Voicing your Concerns for Staff policies additionally give a platform for our employees to raise concerns about poor working.
  • Anti-Bribery and Corruption Policy: The Company is committed to the highest standards of ethical conduct and integrity in its business activities in the UK and overseas. The Company will not tolerate any form of bribery by, or of, its employees, customers, suppliers or consultants.

Due Diligence Procedures

InPhase has implemented a “contract management programme within the InPhase Solution”. This includes:

  • Identification and training of a limited number of key individuals who have authority to purchase material goods and services.
  • A “contracts repository”. The repository includes functionality to identify risks types, including modern slavery. It also identifies the InPhase contract manager and signposts where guidance on MSA is provided and what the responsibilities of the contract manager are in identifying, managing and mitigating risks.
  • Requirement for appropriate due diligence for new suppliers with whom we contract, which will include modern slavery checks.
  • Updated standard terms and conditions of purchasing, which will include provisions concerning compliance with applicable modern slavery laws.

Next Steps

12 months reassessment of the policy, or reactive to any mandatory requirements as applicable.

Approval

This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement. This statement was approved by the directors of InPhase on July 1st 2021 and remains in place unless detailed otherwise in the publication.