UpToDate, Inc. (we, us, our in context) makes this statement voluntarily under the Modern Slavery Act 2015 for the financial year ending 31 December 2021. This statement describes the steps taken to prevent modern slavery in our business and supply chain.
Modern slavery is a crime and a violation of fundamental human rights. Modern slavery takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.
OUR BUSINESS & ORGANISATION'S STRUCTURE
We are part of the Wolters Kluwer group, a global information, software and consultancy provider specialising in health, tax, finance and law. Every year, billions of decisions are made by our customers, in the UK and over 180 countries around the world. Wolters Kluwer supports our customers at each stage, giving them the expert knowledge and software they can rely on. We take this responsibility very seriously.
Our business activities focus on providing trusted clinical technology and evidence-based solutions that help drive effective decision-making and outcomes across the continuum of healthcare.
Our risk profile with respect to human rights-related matters is considered low having regard to: (i) the types of products & services we deliver; (ii) the customers and suppliers we deal with and the jurisdictions in which our suppliers are located; (iii) our highly qualified employees and our policies; (iv) our approved contractors; (v) the terms of our agreements with our suppliers; and (vi) the due diligence process undertaken.
OUR SUPPLY CHAINS
Our business activities include procurement of goods and services and outsourcing/subcontracting. Some goods and services are procured by us directly from third party suppliers (with whom we contract) while others are procured by us through/from the Wolters Kluwer group and its various arrangements for the group's entities.
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
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. Our Modern Slavery Policy reflects our commitment to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place in our supply chains. We are also dedicated to being a responsible partner in society.
FOR OUR VALUES pages: https://www.wolterskluwer.com/en-gb/about-us/company-values
FOR OUR SUSTAINABILITY pages: https://www.wolterskluwer.com/en-gb/about-us/sustainability
Our Supplier Code of Conduct is further described as set forth below.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
We have zero tolerance to modern slavery and human trafficking.
As part of our initiative to identify and mitigate risk we have in place systems to:
- Identify and assess potential risk areas in our supply chains with the help of the group, internal audit, human resources and legal.
- Mitigate the risk of modern slavery and human trafficking occurring in our supply chains.
- Protect whistle blowers.
SUPPLIER ADHERENCE TO OUR VALUES AND ETHICS
Our suppliers are expected to conduct themselves in accordance with the Wolters Kluwer Supplier Code of Conduct (please see the Responsible Supply Chain section) or to have established and committed to an equivalent standard as well as with local laws and regulations.
COMPLIANCE TRAINING FOR OUR EMPLOYEES
Our group's annual online compliance training creates awareness of our company values and business principles, and our other rules of conduct.
EFFECTIVENESS OF MEASURES
We offer various channels for raising concerns and questions, including concerns regarding modern slavery. In particular, Wolters Kluwer provides a communication system allowing employees to anonymously report on any suspected misconduct, including suspected breaches of any law, our Code of Business Ethics, our Supplier Code of Conduct or other policies. Reported concerns are thoroughly investigated appropriate action is taken as necessary to remedy the particular issue or violation. In the future, we will consider additional methods that could be put in place to monitor the effectiveness of the measures described in this statement.
This statement is voluntarily made and constitutes our modern slavery statement for the financial year ending 31 December 2021.
Claire Vadney
Vice President, Finance
UpToDate, Inc.
June 29, 2022