Optum Solutions UK Holdings LTD (The Company)
This statement is made pursuant to Section 54, Part 6 of the UK Modern Slavery Act 2015 (MSA) and sets out the steps the Company has taken to ensure that any form of modern slavery and human trafficking are not taking place in its lines of business and supply chain. Our Company and its subsidiaries are committed to applying and promoting corporate socially responsible practices that respect and protect the human rights of all people we employ, do business with, and serve. As such the Company opposes and prohibits all human rights breaches such as trafficking, forced labour, underage labour, servitude, slavery and slave labour, exceeding the maximum number of contracted hours of daily labour set by applicable laws and regulations or paying associates wages and benefits below the minimum requirements stipulated by applicable laws, regulations and industry standards. The Company has a zero-tolerance policy in respect to modern slavery and is operating associated policies and procedures to protect and safeguard vulnerable workers, gender equality and diversity & inclusion. As part of the Company’s Compliance & Ethics Program, our employees receive annual training on and must adhere to our Code of Conduct. The Code of Conduct, and the various written policies that support it, are designed to create a culture of ethics and integrity and to facilitate compliance with the laws of all jurisdictions in which the Company operates. The Company is operating under the highest ethical business standards and requires its business partners and suppliers to follow the same practices. Our compliance screening processes and enhanced due diligence programmes are tailored to challenges posed by a global network of providers and our global supply chain:
- WorldCheck screening of entities and Special Designated Nationals (SDNs)
- Sanctions restrictions monitoring to identify associates of sanctioned entities that could be tied to human rights violations
- Politically Exposed Persons (PEPs) PEP monitoring connections with individuals in power with opportunity to facilitate or prompt human trafficking activities
- Beneficial ownership
- Negative media publicity
- Risk-based approach prompting enhanced due diligence
We have effective systems and controls in place to prevent unauthorised contracting. Upon entering a new contract, our designated Enterprise Sourcing & Procurement and Compliance team conduct risk assessments, preliminary checks and screening to prevent agents and subcontractors at any tier and at any monetary value from engaging in trafficking in persons and to monitor, detect, and terminate any agents, subcontracts, or subcontractor employees that have engaged in such activities. Company Master Service Agreements include a mandatory Modern Slavery Act clause requiring compliance with the act: “Slavery/Human Trafficking”. At a minimum, the Vendor / Supplier/ Business Partner represents and warrants that (i) to the best of its knowledge, it has not been and is not currently subject to any action, suit, proceeding, or claim formally commenced or pending, or any investigation with respect to slavery or human trafficking, including any actual or claimed violation of the Modern Slavery Act 2015 (the “Modern Slavery Act.”); and (ii) it has not and will not engage in any activity, practice or conduct that would constitute an offence under the Modern Slavery Act.” Our Company reserves the right to change its operational models on short notice to maintain business continuity across Ukraine, Russia, Belarus and surrounding regions, as well as taking into consideration restrictions dictated by US, UK and EU economic sanctions against occupied territories and Special Designated Nationals (SDNs). Our Company does not engage and DOES NOT provide services in Cuba, Iran, North Korea and Syria. In addition, the same status quo applies to Crimea region carved out from Ukrainian territories to Russian's jurisdiction, as well as Donetsk People’s Republic and Luhansk People’s Republic including Kherson and Zaporizhzhia regions prohibiting new investments, the import or export of any goods, services, or technologies, and the financing of such actions. This is similar to the sanctions taken on the Crimea region in 2014.
THE COMPANY RESERVES THE RIGHT TO TERMINATE BUSINESS WITH ANY VENDOR, SUPPLIER OR BUSINESS PARTNER THAT FAILS TO COMPLY WITH OUR CODE OF CONDUCT OR WITH APPLICABLE LAWS AND REGULATIONS.
On 24 March 2025, the UK Government published a fully revised and updated version of its statutory guidance on the transparency in supply chains provisions in section 54 of the Modern Slavery Act 2015. Our Modern Slavery Transparency Statement has been reviewed and updated in the light of the new guidance in addition to PPN 02/23 - Tackling Modern Slavery in Government Supply Chains – Guidance for organisations operating in the public sector and UK public procurement. As a Supplier of healthcare services to the UK Government and the NHS, in 2025 our Company have completed and submitted our Modern Slavery Risk Assessment using MSAT. The MSAT is a modern slavery risk identification and management tool. This tool has been designed to help public sector organisations work in partnership with suppliers to improve protections and reduce the risk of exploitation of workers in their supply chains. Although no risks have been identified as a result, our Company acknowledged tailor-made recommendations generated from your responses and committed to develop new Key Performance Indicators designed to measure our progress on the effectiveness in ensuring slavery and human trafficking is not taking place in our business and supply chains, measured against such key performance indicators (KPIs) as it considers appropriate in the following areas:
- Number of suppliers assessed for modern slavery risk
- Percentage of suppliers with robust modern slavery policies in place
- Number of supplier audits conducted.
- Number of suppliers that have been sanctioned for non-compliance.
- Staff Training and Awareness
- Number of policies and procedures developed to address modern slavery risks.
- Frequency of policy reviews and updates
- Regularly collect data related to your KPIs, using a variety of methods, such as audits, surveys, and reports
- Analyze the data to identify trends and areas for improvement, and report on your progress in your Modern Slavery Statement
- Regularly review and update your KPIs to ensure they remain relevant and effective.
Our 2025 Modern Slavery Risk Assessment has been also conducted and updated taking into consideration new parameters such as:
- the United States’ Bureau of International Labor Affairs (ILAB) List of Goods Produced by Child Labor or Forced Labor
- The Global Slavery Index contains national estimates, calculated by the Walk Free Foundation, on the basis of a predictive model that accounts for individual and country-level risk factors.
This Modern Slavery Act Transparency Statement 2025 has been reviewed and approved by UK Board of Directors 30th April 2025
Robin Sergeant
Director
Optum Solutions UK Holdings Limited