Modern Slavery
CDL Statement of Compliance
Financial Year ended 30th September 2022
Our Business Model
The CDL group of companies (Cheshire Datasystems Ltd, CDL Internet Services Ltd, CDL Production Services Ltd and CDL Vehicle Information Services Ltd) provides products and services into the UK insurance and vehicle information markets. Products include CDL Classic and Strata insurance quotation and administration systems, and price comparison web site applications; services include vehicle information services, systems hosting and management, data analysis and data exchange. CDL is a key service supplier to insurance brokers and insurers and is responsible for the accurate delivery of data sets and EDI.

Services delivered include: software development and support; vehicle information services; service management; application service provision and hosting.

Internal activities include: commercial operations; project management; HR; finance; compliance with legal, regulatory and contractual obligations.

In order to maintain services and activities CDL is reliant on the supply of products and services from: BT, Microsoft, Oracle, Red Hat, Dell, HP, Worldpay, utilities suppliers, Amazon Web Services, and others.

Policies Relating to Modern Slavery Within CDL
In accordance with our Corporate Responsibility, Anti-Bribery and Corruption, and Modern Slavery Policies, and to meet our wider objective to respect the rights of staff and others in the local and wider community, CDL is committed to ensuring that we do not knowingly exploit or benefit from the unlawful treatment of others.

We do not use, or tolerate others' use of, forced labour or human trafficking practices, including the exploitation of children. We will never knowingly do business with customers, suppliers or other business partners who violate these policies.

CDL is committed to social responsibility and has zero tolerance for slavery and human trafficking. We hold ourselves and our supply chain accountable and comply with the provisions of the Modern Slavery Act 2015.

CDL recognises that modern slavery is a complex supply chain issue; we must work in partnership with our customers, suppliers and other organisations to help develop long-term solutions to this issue.

CDL will conduct a periodic review of the policies and procedures implemented by our significant suppliers that ensure their compliance with the Modern Slavery Act 2015, and update this statement annually.

We apply our employment practices in line with, and in certain aspects exceeding, the requirements of UK legislation, to ensure that all employees are properly entitled to work in the UK.

We actively support employee engagement, representation, dialogue and the ability of employees to raise potential concerns or grievances.

To help ensure that there are no obstacles to exposure of any unlawful or unethical practices CDL has implemented a Whistleblowing Policy, including facilities available for staff to report any issues, anonymously if desired, via a third-party organisation.

Training
All staff have been trained on the requirements of CDL's Modern Slavery Policy. CDL ensures that all staff receive training when they join the company, and annually thereafter.

Risk Management
We consider that the greatest risk of slavery and human trafficking is in our supply chain where we undertake procurement activities and where operations and managerial oversight are out of our direct control.

CDL recognises that some of the sectors in which its suppliers operate will be more susceptible to human trafficking and slavery than others, but CDL is committed to driving high standards across all of its supply chains, irrespective of sector.

Where possible, we build long-standing relationships with suppliers and make clear our expectations of business behaviour.

With regards to national or international supply chains, our relationship is preferably with a UK company or branch and we expect these entities to have suitable anti-slavery and human trafficking policies and processes. We expect each entity in the supply chain to, at least, adopt 'one-up' due diligence on the next link in the chain. It is not practical for us to have a direct relationship with all links in the supply chain.

In relation to our own employment practices, we monitor and review:

Employee engagement scores
Issues raised through Public Interest Disclosure
Grievances

In relation to supplier standards, we monitor and review:

Supplier audit results
Suppliers published Modern Slavery Act Statements
Supplier ratings

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