Allscripts Healthcare Solutions, Inc. Statement on Modern Slavery Act 2015
As a healthcare information technology company, Allscripts Healthcare Solutions, Inc. and its affiliates (“Allscripts”) are committed to improving the lives of people around the world. We adhere to the highest moral and legal principles and fully support all efforts to combat slavery, child labour, and human trafficking. As a result, we have created policies, processes and procedures designed to prevent these unlawful practices in our business and our supply base. The following statement outlines the steps that Allscripts has taken in support of the UK Modern Slavery Act 2015.
2. WHAT CONSTITUTES SLAVERY TODAY AND HOW DOES THE UK MODERN SLAVERY ACT PREVENT IT
Modern slavery is an international crime affecting an estimated 40 million people worldwide. This growing global issue transcends age, gender and ethnicities. It includes victims trafficked from all parts of the world, who are forced illegally to work against their will across many different sectors such as agriculture, hospitality, construction, retail and manufacturing. The Modern Slavery Act 2015 requires commercial organizations supplying goods or services with a turnover of above £36 million to prepare and publish an annual ‘Slavery and Human Trafficking Statement’. The statement must set out the steps an organization has taken, if any, during its financial year to ensure that slavery or human trafficking is not taking place in its supply base.
3. OUR ORGANISATION'S STRUCTURE AND BUSINESS
Allscripts is a leader in healthcare information technology solutions that advance clinical, financial and operational results. Our innovative solutions connect people, places and data across an Open, Connected Community of Health™. Connectivity empowers caregivers to make better decisions and deliver better care for healthier populations. Allscripts is one of the largest public companies focused exclusively on healthcare information technology globally. Allscripts is divided into numerous business units and offers healthcare providers, payers and life sciences companies globally a complete portfolio of clinical, financial, population health management, transaction and managed IT services and other solutions. As of December 31, 2017, approximately 75,000 physician practices, 3,400 hospitals and 100,000 coordinated community care organizations use our EHRs, products and services. Allscripts operates in 13 countries through local subsidiaries, including Australia, Canada, India, Israel and the United Kingdom.
4. OUR SUPPLY BASE
Our supply base consists of over 1,000 suppliers across a wide range of business sectors, primarily including, but not limited to, information technology, marketing, consulting, professional services and facilities management. Over eighty percent of our supplier related spend is concentrated within twenty percent or less of our supply base. We hold our suppliers to the same ethical standards that we impose within Allscripts and are committed to conducting business with suppliers who comply with laws and regulations that are applicable to their business, including laws relating to slavery and human trafficking. Although, the clear majority of our supply base performs in a business sector publicly known to be low risk as it pertains to slave labor and human trafficking, we are committed to end slavery and human trafficking through consistent periodic review of our supply base across many performance metrics including compliance.
5. OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
Our Code of Conduct requires our employees and representatives to act ethically, with transparency, and to comply with all laws. Our Code of Conduct encourages all employees to report violations of law and provides a variety of channels for doing so. Allscripts values the help of employees or others who identify potential problems that need to be addressed and prohibits retaliation against any person or entity who honestly raises an issue of concern. In addition to our Code of Conduct, we also maintain Policies directed to specific laws and practices. Allscripts’ Policy on Slavery and Human Trafficking specifically prohibits slavery, child labour or human trafficking in our business and prohibits us from utilizing any supplier that does not comply with the Modern Slavery Act 2015 or other relevant laws. Allscripts periodically assesses the risk of violation of law, including the Modern Slavery Act 2015 and has created a system of controls to effectively manage these risks. Given the types of products and services offered by Allscripts the risk of violating the Modern Slavery Act is low.
6. DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk we have a formal supplier registration process by which prospective and existing suppliers are reviewed by a cross functional team against many factors, one of which is compliance, and the ability to comply on an ongoing basis. We have now added reviews focused on compliance with the Modern Slavery Act and are in the process of implementing them.
We have or will have in place systems to:
6.1 Identify and assess potential risk areas in our supply base.
6.2 Mitigate the risk of slavery and human trafficking occurring in our supply base.
6.3 Monitor potential risk areas in our supply base.
6.4 Protect whistle blowers.
7. SUPPLIER ADHERENCE TO OUR VALUES AND ETHICS
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply base and contractors comply with our values. We have in place a supply base compliance program. This program consists of a formal supplier registration and review process which is undertaken first upon initiation of a business relationship with a new supplier and periodically thereafter. We also have continuous monitoring of various media outlets and data sources for information pertaining to our supply base.
We have a compliance team, which has representatives from the following departments:
7.2 Compliance and Audit
7.4 Human Resources
8. AWARENESS AND TRAINING
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply base and our business, we provide annual training to our employees. Our effectiveness in combating slavery and human trafficking is increased through these awareness efforts.
9. FURTHER STEPS
Following a review of the effectiveness of the steps we have taken thus far to ensure that there is no slavery or human trafficking in our supply base we intend to continue our commitment to combat slavery and human trafficking through requiring attestation from suppliers that they do not take part in any such activity, as well as, bolstering our continual monitoring of our supply base.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Allscripts disclosure on slavery and human trafficking statement for 2019-2020.
Paul M. Black , CEO Allscripts Healthcare Solutions, Inc.
Last Updated: September 2019