Modern Anti-Slavery Policy

Introduction

This statement has been published in accordance with Section 54 of the Modern Slavery Act 2015. It sets out the steps taken by Bering Limited and its trading subsidiaries to seek to ensure that slavery and human trafficking is not taking place in its supply chains or in any part of the business.

Organisational structure and business

Bering Limited is a UK based software and services SME specialising in development of Artificial Intelligence-enabled Clinical Decision Support Systems. Our business operates primarily within the UK and our key inputs are our skilled people. Given the nature of the Company’s business the Board and management consider the risk of modern slavery in the business or within its supply chain to be low.

Policies on modern slavery

Bering is committed to conducting business responsibly. It seeks to ensure that its supply chains operate to those same high standards, including third party employment practices, workplace conditions and, more specifically, the prevention of forced, bonded and trafficked labour. This is upheld through the Company’s policies and processes, and is fully supported by the Board. Relevant policies include: whistleblowing, code of ethics and standards of business conduct, anti-bribery and corruption and anti-tax evasion.

Supplier on-boarding process – due diligence and risk assessment

All current and prospective UK third party suppliers are required to demonstrate a commitment to and an ongoing compliance of the Modern Slavery Act 2015.

Our comprehensive supplier on-boarding process includes specific questions related to the Modern Slavery Act 2015 and is supported by a formal risk analysis to determine whether to work with the company, based on the nature of the supplier, size of company and its location.

As in previous years Bering’s UK procurement team continued to audit its key suppliers and did not find any instance contravening the Modern Slavery Act 2015. The supplier audit is a continuous process which measures the effectiveness of our policies and procedures, and ensures adherence to the Act is maintained as a requirement of doing business with Bering Limited. Any companies who are found to be non-compliant are subject to a risk analysis review where they are given the opportunity to comply within an agreed period. Where compliance is not achieved, an alternative supplier is sourced and the relationship with the non-compliant supplier is terminated.

Where Bering has an extended supply chain, particularly with major technology vendors, it relies on their respective modern slavery statement to be accurate and appropriately applied.

Training

Bering continues to train employees that interface with third party organisations. The aim is to help managers and their teams to identify and report any signs of Modern Slavery, to be compliant with the policy and to help Bering fulfil its corporate role as an ethical company and with a transparent supply chain.

Dr. Ignat Drozdov

Managing Director