Cura Systems International Ltd | Modern Slavery Statement 2022

This statement is made pursuant to the Modern Slavery Act 2015 (the Act) that came into effect on 29th October 2015. Section 54, Part 6 of the Act requires UK commercial organisations carrying out business in the UK supplying goods or services with an annual turnover of at least £36 million to publish a modern slavery and human trafficking statement for each financial year of the organisation.

Whilst our turnover is less than least £36 million, we full support the aims the Modern Slavery Act 2015 and is an integral part of the core values of Systems International Ltd and its subsidiaries (together “Cura Systems”).  Cura Systems is fully committed to doing business the right way and staying true to our core values.

We categorically state that in accordance with Section 54, Part 6 of the Act, we meet these criteria and this statement is made for the financial year 2022 for all of Cura Systems and its people throughout the world.

As a software company operating in first world countries, we do not carry the same high-level slavery risk as companies operating in the retail or manufacturing sectors, however, this statement covers those areas within our business supply chain, which may present a potential slavery risk. We are committed to understanding the modern slavery risks and to ensuring there is no modern day slavery in our business and supply chains.

We confirm there were no instances of slavery or human trafficking concerns raised to us during the financial year under review.

Cura Systems – Organisational Structure and Background

Cura Systems is the developer and distributor of Cura, a suite of systems designed specifically for the long-term care sector.  Our solutions allow care records to be digitised at the point-of-care.

Our Business and Supply Chain Risks

Cura Systems takes a zero tolerance stance in relation to the use of slavery or human trafficking in its direct supply chain. Given the nature of our business model, we believe the risk of modern slavery in our supply chain is low compared to businesses operating in other sectors such as manufacturing and retail. We have not identified any instances of modern slavery occurring in our supply chain. However, we recognise that there is no room for complacency and will continue to work to enhance our policies and procedures and measure awareness within our business.

All our spend commitments are made using written contracts and we do not pay cash for services. Our major suppliers are mainly large multinational companies who have their own ethical policies and standards of behaviour in place.

Our Policies, Due Diligence and Effectiveness

Our relationship with our employees begins at the hiring stage, and we operate a fair and in-depth recruitment selection process for all of our hiring decisions. This selection process, where permissible by local laws and the recruitment policy, it includes obtaining documented proof of the individual’s right to work in the country in which they are to be employed. We aim to pay colleagues at least the minimum wage rate applicable in the geographical location in which the individual works. We also pay great importance on investing in our employees’ development, including providing them with the knowledge and tools they need for them to do business the right way in line with our organisational values. We aim to ensure that everyone is treated fairly throughout their time with us, providing them with appropriate employee rights and benefits that they are entitled to by law as a statutory minimum, many of which are enhanced to match competitive standards.

Our Code of Conduct provides unambiguous guidance for all colleagues on how we do the right thing and sets clear expectations across Cura Systems for compliance with ethical standards including in relation to modern slavery concerns.

Our supply chains are based for the most part in the UK and Asia, with some additional supply from the US, and include distributors of 3rd party products (hardware, licensing, and infrastructure), suppliers of indirect services such as professional services, and resellers.

We conduct due diligence on all suppliers as they are brought into the business, before allowing them to become one of our suppliers. This due diligence includes:

• Checks to determine the financial stability of the supplier
• Checks on compliance with regulations
• Confirmation of an anti-corruption policy
• Confirmation of a business continuity plan
• Risk assessment of all suppliers and clarify that they have taken the appropriate steps within their business to eradicate modern slavery in their organisation and in their supply chain
• Notification to all current suppliers of our expectations around the prohibition of modern slavery

Our supplier code of conduct has been communicated to our existing suppliers and associated companies to remind them of our policies and what we expect from those we do business with. It also serves as a tool to set the right standard with any new suppliers going forward. Each supplier is expected to commit to the Code and adhere to it. The Supplier Code forms part of any supplier relationship with Cura Systems going forward, and we will not deal with any suppliers who do not commit to or breach the Supplier Code.

Cura Systems reviews its standard supplier terms and conditions annually and it is included in audit provisions and clearly identifies that supplier violations are grounds for immediate termination.

Our Training and Staff Terms & Conditions of Employment

Cura Systems maintains policies and procedures staff manuals and Terms & Conditions of Employment that deal with matters such as treating employees fairly, protecting human rights such as elimination of discrimination. All new starters are provided with full on-boarding, and refresher training is available to all staff at any time via their manager to emphasise the importance of integrity in the workplace. There is annual refresher training in place for staff whose roles are better placed to spot potential incidents of modern slavery within our supply chain.

As with any company policy, disciplinary procedures are included and are being updated to reflect the process in the event of any violation of the Act or Cura Systems policies in relation to it.

Responsible Business

Cura Systems is committed to maintaining a culture of integrity, transparency, and accountability to ensure compliance with all applicable laws. Our business is answerable to all its stakeholders, not simply our investors, and we believe that the benefits of being a good corporate citizen go far beyond the bottom line. We strongly believe in the rule of law and we are committed to comply with all relevant international and local laws wherever we operate. We expect the same from our business partners, contractors, agents and joint ventures to do the same.

Review

This statement will be reviewed on an annual basis and published on the Cura Systems website, www.cura.systems

Charmaine Chong
Cura Systems Group CEO

21 July 2022

This Policy has been approved by the Cura Systems Board of Directors.

Entities to which this statement applies: Cura Systems International Limited, Cura Advanced Technologies Limited, LANWorks Private Limited; GiftBox International Limited; LANWorks (Sdn) Bhd.