Modern Slavery Statement
A. ORGANISATION
This statement applies to RIVIAM Digital Care (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year 2025-2026.
B. DEFINITIONS
The Organisation considers that modern slavery encompasses:
- Human trafficking;
- Forced work, through mental or physical threat;
- Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
- Being dehumanised, treated as a commodity or being bought or sold as property;
- Being physically constrained or to have restriction placed on freedom of movement.
C. COMMITMENT
The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom.
D. ORGANISATIONAL STRUCTURE
The labour supplied to the Organisation in pursuance of its operation is carried out in the United Kingdom (Greater London, East of England, West Midlands, East Midlands, Yorkshire and the Humber, Southeast England and Southwest England).
RIVIAM Digital Care provides digital solutions for health and social care services, enabling better communication, co-ordination and care delivery. Our primary operations involve software development, IT services and client support. Products, services and software development are provided in-house rather than in a supply-chain method.
E. SUPPLY CHAIN STRUCTURE
In order to fulfil its activities, the Organisation’s main supply chains include those related to:
- Technology and IT infrastructure: Hardware, software licenses, cloud services and network providers.
- Professional services: Consulting, legal, accounting and marketing services.
- Office supplies and facilities: General office equipment, utilities and building maintenance.
- Personnel: Recruitment agencies for temporary or permanent staff.
Given the nature of our business as a software and IT services provider, our supply chain is generally considered to be at a lower risk of modern slavery compared to industries involving manual labour or complex international manufacturing. However, we remain vigilant and recognise that risks can exist in any supply chain.
F. ORGANISATIONAL POLICIES
The Organisation has the following policies which further define its stance on modern slavery
RIVIAM Digital Care 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:
- Whistleblowing Policy: We encourage all our employees, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, RIVIAM Digital Care. Our whistleblowing policy is designed to ensure that employees can raise concerns without fear of reprisal.
- Employee Code of Conduct/Ethics Policy: This policy makes clear to employees the actions and behaviour expected of them when representing RIVIAM Digital Care. We strive to maintain the highest standards of employee conduct and ethical behaviour.
- Supplier Code of Conduct/Procurement Policy: We are committed to ensuring that our suppliers adhere to the highest standards of ethics. Our procurement policy requires suppliers to confirm that they comply with all applicable laws and regulations, including those related to modern slavery and human trafficking. We expect our suppliers to have their own robust policies and procedures in place to address these issues.
- Recruitment Policy: We operate a robust recruitment policy, including conducting eligibility to work in the UK checks and a DBS check for all employees to safeguard against human trafficking or individuals being forced to work against their will.
G. ASSESSING AND MANAGING RISK
The Organisation considers its main exposure to the risk of slavery and human trafficking to exist as follows:
We assess the risk of modern slavery in our business and supply chains as follows:
- Internal operations: We consider our internal operations to be low risk due to the nature of our work, our recruitment processes and our commitment to fair employment practices.
- Supply chain: While generally low risk, we acknowledge that certain tiers of our supply chain, particularly those involving international components or services, may carry a higher inherent risk. We continuously monitor and review our supplier relationships.
- Geographical risk: We consider the geographical locations of our suppliers and their operations, paying closer attention to regions identified as having a higher prevalence of modern slavery.
We aim to mitigate any identified risks through our due diligence processes, contractual agreements and ongoing monitoring.
In general, the Organisation considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
H. DUE DILIGENCE IN RELATION TO MODERN SLAVERY
The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.
RIVIAM Digital Care undertakes due diligence when considering new suppliers and regularly reviews its existing suppliers. Our due diligence process includes:
- Supplier assessment: For new and significant suppliers, we assess their policies and practices regarding modern slavery. This may involve requesting information on their own due diligence processes, risk assessments and training programs.
- Contractual clauses: Our contracts with suppliers include clauses requiring compliance with all applicable laws, including those related to modern slavery and human trafficking.
- Risk-based approach: We adopt a risk-based approach, focusing our efforts on areas where we identify a higher potential for modern slavery risks within our supply chain.
I. TRAINING
The Organisation provides the following training to staff to effectively implement its stance on modern slavery.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide relevant training to our staff. All employees are made aware of our policies and encouraged to report any concerns. Key personnel involved in procurement and HR receive more detailed training on identifying and addressing modern slavery risks.
- MONITORING AND EVALUATION
The Organisation has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains.
While the direct impact of modern slavery is difficult to quantify, RIVIAM Digital Care monitors the effectiveness of its efforts to combat modern slavery through the following:
- Number of employees trained on modern slavery awareness.
- Number of new suppliers screened for modern slavery risks.
- Number of concerns raised via our Whistleblowing Policy related to modern slavery.
- Review of supplier compliance with contractual obligations related to modern slavery.
K. STEPS
The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:
RIVIAM Digital Care will continue to review and enhance its approach to combating modern slavery. In the coming year, we plan to:
- Regularly review and update our policies and procedures to reflect best practices and evolving legal requirements.
- Continue to raise awareness among our employees and suppliers about the risks of modern slavery.
- Strengthen our due diligence processes for high-risk suppliers.
L. MODERN SLAVERY COMPLIANCE OFFICER
The Organisation has a Modern Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation obligations in this regard.
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.
Date of approval by Paul Targett, CEO and Founder
Date 28th May 2025