INTRODUCTION
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.
Noble Healthcare 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.
Noble Healthcare is 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 of 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.

ORGANISATION’S STRUCTURE
Noble Healthcare Limited. Is a private limited company (13121233) registered in the UK (71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ). This statement covers the business activities of Noble Healthcare which are as follows:
· Insight / Data Analytics: Detailed analysis of customer organisation, using wide range of tools and methodologies to identify actions needed to increase visibility, compliance and transparency
· Procurement: We work alongside customers to cut costs, make existing contracts work harder, and reduce any inefficiencies to free up maximum funds.
· Transformation: Helping customers adapt and improve their performance across procurement, finance, operations, service and leadership.
· Resourcing: provision of market leading procurement and transformation experts to address customer recruitment needs – either ad hoc or long term.
 
OUR SUPPLY CHAINS
Our supply chains include the procurement technology providers and back office support.

APPROACH TO 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 Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
 
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk we:
· Build long-standing relationships with local suppliers and make clear our expectations of business behaviour;
· Have a policy of “knowing our customer” to ensure that we are contracting with appropriate businesses;
· With regards to national or international supply chains, our point contact is preferably with a UK company or branch and we expect these entities to have suitable anti-slavery policies and processes.
· We have in place systems to encourage the reporting of concerns and the protection of whistle blowers.
 
SUPPLIER ADHERENCE TO OUR VALUES AND ETHICS
We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors to comply with our values.

TRAINING
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide briefings to our Directors and employees.

OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
· Completion of audits by the Board of Directors and the Head of Quality;
· Use of staff monitoring and payroll systems; and
· Level of communication and personal contact with next link in the supply chain and their understanding of, and compliance with, our expectations.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the current financial year.