This Statement sets out Heywood’s approach to modern slavery risks and the steps it takes to ensure there is no slavery or human trafficking in its operation or its supply chain.

This statement covers the financial year ending 30 April 2024.

Whilst this statement refers to UK-specific legislation, we are committed to ensuring compliance with any equivalent legislation in all jurisdictions where we operate.

Heywood is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisation structure

The Heywood Group (“the Group”) incorporates Heywood Limited as the primary trading entity, along with its UK group affiliates Apus Bidco Limited, Aquilaheywood Limited, i-Connect Software Limited, and ATMOS Data Services Limited. The Group has recently acquired a New Zealand based business called Idiom and, as such, those entities are now part of the Group.

The Group’s business operations are predominantly in the software and technology industry, providing a range of pensions administration and finance solutions along with a wide-ranging portfolio of ancillary products and services.

Relevant policies, practices, and values

We operate the following policies that support our approach to modern slavery and human trafficking:

• Whistleblowing Policy - We encourage all our employees to report any concerns they may have. Our whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation.
• Code of Conduct - Our Code of Conduct makes clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour at all times.
• Human Rights Policy - Our human rights policy sets out our position of respecting and protecting human rights.
• Recruitment - We have robust recruitment and onboarding processes with multiple checks built in to ensure that all individuals employed by us have the legal right to work, are paid a fair salary, are of the required minimum age to work, and are not subject to human trafficking or forced labour.
• Employees - We ensure that all employees complete training to raise awareness of modern slavery issues, including how to identify the signs of slavery and human trafficking; resources and support available; what initial steps should be taken if slavery or human trafficking is suspected; and how to escalate potential slavery or human trafficking issues to the relevant persons within our organisation.
• Our Company Values - our core values contain themes of honesty, respect, integrity and doing the right thing – all of which set out the behaviours we expect of our employees.

Supply chain

All suppliers and business partners that we work with are subject to extensive due diligence which includes requiring confirmation that they comply with the Act, that no form of modern slavery exists in their workforce or supply chain, and that they provide safe and fair working conditions for all staff. Our due diligence includes, as an example:

• assessing our supply chain for any particular product or geographical risks of modern slavery and human trafficking;
• evaluating the modern slavery and human trafficking risks of each new supplier;
• on-going regular audits of suppliers to ensure continues compliance with modern slavey and human trafficking requirements.