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Modern Slavery Statement

Updated September 2018
Proactis Holdings plc (AIM: PHD) is a global software company with over 15 years of experience in delivering and supporting software solutions that help customers to achieve greater control and visibility of their spend.
As a software company, Proactis does not have an extensive range of local or international suppliers where modern slavery or human trafficking would generally be a material risk. However, we are committed to acting ethically and with integrity in all our business relationships. Proactis has spent the past year implementing and enforcing effective systems and controls to ensure slavery and human trafficking does not take place anywhere in our business or supply chains.
We have reviewed our systems and controls in relation to the Modern Slavery Act (“the Act”). This involved:
  1. Identifying, assessing and monitoring potential risk area sin our supply chains; and
  2. Mitigating the risk of slavery and human trafficking occurring in our supply chains.
Proactis has reviewed how we engage with our supplier base to ensure that they will be compliant with the Act. 
The first part of this has been to review our supply chains and businesses in territories that fall within the criteria of the Act (that is, those companies which carry on business in any part of the UK and supply goods or services with a minimum annual turnover of £36million). This initial review has taken place and is currently extending this review globally, across the wider Proactis Group.
Proactis has also developed a Supplier Code of Conduct policy (available here) and has been updating other internal policy documents as appropriate. 
The Proactis Board has overall responsibility for ensuring the new policies comply with our legal and ethical obligations and that all those under our control comply. The Proactis Group Compliance and Quality Manager has primary and day-to-day responsibilities for implementing the policy and monitoring its use and effectiveness.
The following Proactis entities fall within the criteria defined in the Act:  Alito Ltd, Proactis Limited, EGS Group Holdings Ltd, EGS Group Ltd, Intelligent Capture Ltd, Intelligent Capture Managed Services Ltd, Perfect Commerce UK Ltd, InterSources (UK) Ltd, Proactis Overseas Ltd, Due North Ltd and Millstream Associates Ltd. 
This statement is made pursuant to section 54(1) of the Act and has been approved by Proactis’ Board of Directors.
Signed by Alan Aubrey
Title: Chairman
Proactis Holdings plc

Last updated: September 2018 | Next review: September 2019