Apira Anti-Slavery and Trafficking Policy Statement 


Prepared by Alan Brown, Director, Approved On Behalf Of The Board

Updated August 30th 2023


About Us

Apira are a digital transformation consultancy working predominantly within the NHS.


This policy statement describes the steps taken by Apira to prevent Modern Slavery and Human Trafficking within our business and supply chains.

  1. Apira Limited have reviewed its business in relation to Modern Anti-Slavery and Trafficking. We are exempt from the compulsory modern anti-slavery policy as our turnover is below £36m. Even so, we are committed to preventing Modern Slavery and Human Trafficking within our business and supply chains.
  2. As an organisation, our customers and suppliers are UK based, we do not have relationships with organisations based in countries without mature labour laws.
  3. We are ‘Real Living Wage’ employers. We ensure all suppliers and contractors pay their staff a living wage.
  4. Due to the skill requirements and experience we require from staff and suppliers; we are satisfied that the likelihood of Modern Slavery occurring within our business or a supplier’s organisation is very unlikely. However, we do monitor this and ensure steps are in place to assess and manage this risk.
  5. We have set out below our voluntary modern anti-slavery and trafficking statement.
  6. Apira will ensure all staff, suppliers, and contractors comply with the policy statement.
  7. We will also display the statement on our website.

The policy statements

  1. Modern Slavery is a crime and a violation of fundamental human rights. It 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.
  2. Apira has a zero-tolerance approach to Modern Slavery, and we are committed 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 anywhere in our own business or in any of our supply chains.
  3. We are also committed to ensuring there is transparency in our own business and in our approach to tackling Modern Slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all our contractors, suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
  4. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
  5. This policy forms part of any employee’s contract of employment, and we may amend it at any time. We do carry out employment checks prior to employment to ensure potential employees are legally allowed to work in the UK and as part of our on-boarding procedures, we ensure individuals are aware of and understand our policies.

Responsibility for the policy 

  1. The Directors are responsible for ensuring this policy complies with our legal and ethical obligations and that all those under our control comply.
  2. The People Management Group has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering Modern Slavery.
  3. Management at all levels is responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of Modern Slavery in supply chains.
  4. You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Commercial Manager.

Compliance with the policy

  1. You must ensure that you read, understand and comply with this policy.
  2. The prevention, detection and reporting of Modern Slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
  3. You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.
  4. You are encouraged to raise concerns about any issue or suspicion of Modern Slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
  5. If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your manager as soon as possible.
  6. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of Modern Slavery, raise it with your manager.
  7. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment due to reporting in good faith their suspicion that Modern Slavery is taking place in any part of our own business or in any of our supply chains. No one should receive detrimental treatment, such as dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe you have suffered any such treatment, you should inform our People Management Group Chair, Alan Brown or Freedom to Speak Up Guardian, Rupal Thakarshi. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.

Communication and awareness of this 

  1. Training on this policy and on the risk our business faces from Modern Slavery in its supply chains forms part of the induction process for all individuals who work for us. Staff will be provided with regular refresher training.
  2. Our zero-tolerance approach to Modern Slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate.

Breaches of this 

  1. Any employee who breaches this policy will face disciplinary action, resulting in dismissal for misconduct or gross misconduct.
  2. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.