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.
The Parent Company (Optum Solutions UK Holdings Ltd) and its subsidiaries (Optum Health Solutions UK Ltd and Optum UK Solutions Group Limited), 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.
This Modern Slavery Act Transparency Statement 2022 has been reviewed and approved by Optum Solutions UK Holdings Ltd Board of Directors 23 March 2023.
Optum Solutions UK Holdings Limited