Modern Slavery Statement

IRIS Software Group

Modern Slavery Statement – Financial year 23/24

Introduction

This statement sets out IRIS Software Group’s (“IRIS”) commitment to combat the practice of modern slavery, forced labour and human trafficking. It is also to understand the potential modern slavery risks related to its business and implement steps aimed at ensuring no slavery or human trafficking takes place in its own business and its supply chains. This statement relates to actions and activities during the financial year 1st May 2023 to 30th April 2024. The statement is IRIS’ commitment to act ethically by taking steps within its direct structures and wider sphere of influence to ensure that modern slavery, as set out in the Modern Slavery Act of 2015, is not taking place.

This statement will be reviewed annually by IRIS executives in line with its financial planning year end, ending 30th April.

Organisational structure and supply chains

This statement covers the structure and activities of IRIS including its subsidiary companies (as defined under the Companies Act 2006):

The Organisation is a leading provider of business-critical software and services. It connects accountants, educational establishments, businesses, and their employees enabling them to efficiently manage their financial, compliance and human capital resource requirements to achieve success. IRIS offers a broad range of specialist accountancy, financial management, human resource management and payroll solutions – delivered as a choice of integrated cloud-based and on-premises software and applications.

IRIS’ contractors and suppliers are primarily based within the UK, U.S.A and the EU.

Products, services, and software development are generally provided in-house rather than in a supply-chain method.

Countries of operation and supply

United Kingdom – majority of business conducted within the United Kingdom.

North America – to which a portion of the Organisation’s operations and customers are located, including PSI Payroll Services Inc. operating in Canada, and IRIS Americas, Doc.it, Conarc Inc, AccountantsWorld, Apex, myPay (Creative Solutions Software Corp) and Practice Engine Systems Inc.

The European Union and the rest of the world – to which a portion of the Organisation’s staff and customers are located.

India: IRIS KPO Resourcing located in India is a subsidiary of the Organisation, which provides business process outsourcing services for the Organisation’s customers based primarily in the United Kingdom.

Australia – to which a small portion of the Organisation’s staff and customers are located.

IRIS’ procurement procedures follows a defined pathway with authorised personnel within the management structures ensuring third-party organisations, within the supplier/contractor pool and other companies that may be engaged with, are expected to ensure their goods, materials, and labour-related supply chains:

Fully comply with the Modern Slavery Act 2015; and are:

Transparent, accountable, and auditable, and;

Free from ethical ambiguities.

Relevant policies

IRIS operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

IRIS Anti-Slavery Policy:

Described in more detail below under ‘Awareness-raising programme’.

Whistleblowing Policy: IRIS encourages all workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of IRIS. The whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.

Employee Code of Conduct: The code makes clear to employees the actions and behaviour expected of them when representing the Organisation.

IRIS uses only specified, reputable employment agencies to source labour and verifies the practices of any new agency it is using before accepting workers from that agency.

Risk assessment

IRIS has reviewed material suppliers and assesses whether any risks of slavery or human trafficking arise. It does not consider that key relationships with professional or business services suppliers give rise to material risks in this area. Risk may have the potential to arise in relation to internal facilities management, catering, and the supply of office electronic equipment. Risk is managed using suppliers who are considered to be reputable, and it has been specifically requested that all material regular suppliers confirm that their own business activities do not involve slavery or human trafficking.

Steps taken by the Organisation since May 2023

(A) Management responsibility and general awareness

Agreed management responsibility for this statement and the IRIS Anti-Slavery Policy has received unanimous endorsement from the Board;

Raised general organisational awareness;

Reported progress to the executive management team and the Board;

Efforts made to raise awareness of this published statement;

Prepared the next applicable annual statement.

(B) Risk assessment

IRIS has undertaken assessments using legal, risk and procurement teams to determine risk exposure.

Included the Modern Slavery Act 2015 within IRIS’ statutory and regulatory compliance risk assessment procedures to ensure the risk continues to be flagged, assessed, and appropriately addressed.

Asked suppliers to confirm their compliance with the Act during the commercial due diligence process.

IRIS seeks to impose adequate and robust contractual provisions relating to modern slavery or human trafficking compliance by applicable suppliers doing business with the Organisation. IRIS:

Acts promptly where a compliance breach has been identified or flagged;

Continues to feedback lessons learnt into the compliance risk management process;

IRIS is committed to investigating any credible report of potential compliance violations and discrimination or retaliation against individuals reporting these is strictly prohibited. All communications received are treated confidentiality and respectfully. In the prior financial year, we received no indications of concerns relating to forced labour or trafficking via external or internal channels.

Steps to take during the financial year 1st May 2023 to 30th April 2024

(A) Risk assessment

Commence a review exercise of this policy against IRIS’ activities in relation to any newly acquired entity that may be incorporated within the Organisation. Generally, continuing to establish whether the approach taken by the Organisation follows emerging best practice by:

Assessing and interpreting any recent or emerging case law and best practice;

Benchmarking activities against statements and action plans undertaken by similar organisations; and

Re-evaluating the risk of non-compliance as part of the cyclical compliance risk register assessment;

Continuing to ask suppliers to confirm they are compliant when conducting commercial due diligence.

(B) Risk mitigation

Act promptly where a compliance breach has been identified or flagged;

Continue to feedback lessons learnt into the compliance risk management process;

(C) Training

Staff are required to complete compulsory training in company policies and procedures at regular intervals.

Awareness-raising programme

As well as training staff, IRIS has raised awareness of modern slavery issues by producing an IRIS Anti-Slavery Policy that is introduced to staff as part of the induction process and made available on the Organisation’s intranet thereafter.

The IRIS Anti-Slavery Policy explains to staff:

The basic principles of the Modern Slavery Act 2015;

How employees can identify and prevent slavery and human trafficking; and

What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the Organisation.

Supply chains

To ensure suppliers are paid on time, the Organisation follows a set payment run timetable.

Board approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Organisation’s statement for the financial year ending 30th April 2024.

This statement has been approved by IRIS Board of Directors, who will review and update it annually.

Companies within the IRIS Software Group which this statement applies to:

123Comms Limited

Accountants World LLC

Apex Software

APS Global Limited

Atomic IT Limited

Bacsflow Limited

Biostore Limited

Blayhall Professional Limited

Bridgehead (Europe) Limited

Bridgehead (UK) Limited

Conarc Inc

Creative Solutions Software Corp

Datacode Tech Limited

Dataplan Holdings Limited

Dataplan Payroll Limited

Doc-It Corp

Doc-It Holdings Inc

Doc-It Inc

Eurowage Limited

FMP Global Bidco Limited

FMP HR and Payroll Software Limited

Galaxy Payroll Limited

Harper Morris (Payroll) Limited

HMP Associates Limited

Hosted Accountants Limited

Indigo Marketing Limited

Innervision Management Limited

IRIS Americas Inc.

IRIS Bidco Limited

IRIS Business Software Limited

IRIS Canada Holdings Limited

IRIS Capital Limited

IRIS Debtco Limited

IRIS Global Inc.

IRIS Group Limited

IRIS Holdings Limited

IRIS KPO Resourcing (India) Private Limited

IRIS Midco Limited

IRIS Payroll Software Limited

IRIS Payroll Solutions Limited

IRIS Resourcing Limited

IRIS Software Group Limited

IRIS Software Limited

IRIS Software Technical Centre S.R.L

IRIS US Holdings Limited

iSAMS Limited

iSAMS Pty Limited

Kashflow Software Limited

Kinetic Marketing & Design Limited

MCN Associates Limited

Net-worx (2001) Limited

Paycheck Plus Payroll Service Ireland Limited

Paycheck Plus UK Limited

Payplus Limited

Phroot Limited

Practice Engine Systems Inc.

PS Financials Limited

PSI Payroll Services

PTP Software Limited

Results Squared Limited

Sandgate BG Limited

Sandgate Systems Limited

Senta SaaS Limited

Staffology Limited

Star Professional Software Solutions Limited

Sweep Limited

Taxfiller Limited

The Practice Engine Group Limited

Troncmasters Limited

Truancy Call Limited