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Optum UK
Modern Slavery Act Transparency Statement 2021

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 and such as trafficking, forced labour, underage labour, servitude, slavery and slave labour, exceeding maximum number of hours of daily labour set by applicable laws and regulations or associates wages and benefits below the requirements stipulated by applicable laws, regulations and industry standards.

The Company 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.

Upon entering into 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 Ac t 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 . Vendor / Supplier / Business Partner shall implement due diligence procedures for its Vendors, agents, representatives, vendors or other third party resources (collectively, “Third Party Resources”) to ensure that such resources comply with the principles of the Modern Slavery Act.”

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.

Ratified at the Board of Directors meeting on 9th March 2021 and duly authorised by:

SERGEANT, Robin Charles Norman - Board Director and General Manager

ANDERSON, Neil David – Board Director and Senior Accounting Officer

MOURA, Ricardo Assuncao – Board Director and Director Finance