Modern Slavery Act Transparency Statement

Overview

Global Healthcare Exchange, LLC and its subsidiaries (collectively, “GHX”) are committed to preventing slavery and human trafficking in our global operations.  This document constitutes GHX’s statement for the financial year ending December 31, 2016 pursuant to Section 54 of the United Kingdom Modern Slavery Act 2015. 

Business

GHX subsidiaries are located in the United States, Canada, and Europe, including the United Kingdom.  We are a technology and services company helping healthcare providers, suppliers, distributors, and group purchasing organizations to automate their supply chain processes. 

Supply Chain

Although our business involves helping customers with supply chains that are often large and complex, GHX’s own supply chain is relatively simple, and consists primarily of professional services, technology-related goods, and office supplies.  Overall, GHX considers its supply chain to present a very low risk for slavery and human trafficking. 

GHX Policy

GHX does not tolerate slavery or human trafficking in any form.  We are committed to keeping our operations and supply chain free of slavery and human trafficking, and to working with vendors who do the same. 

Due Diligence

With respect to our own workforce, GHX complies with applicable wage and hour laws, and benchmarks salaries to verify that our employee compensation is competitive.  Our engagements for contracted services generally require skills and training that reduce the risk of slavery and human trafficking.  GHX seeks to work with reputable vendors with appropriate credentials.  We conduct additional due diligence with respect to our major services vendors located in countries outside the United States, Canada, and Europe.  GHX generally purchases goods through major suppliers and resellers, and we do not conduct additional due diligence on such vendors beyond our normal vendor engagement processes. 

Because we consider our operations and supply chain to present a very low risk for slavery and human trafficking, we do not specifically train our personnel on that issue.  However, GHX does maintain mechanisms for reporting violations of law and of our compliance requirements.  Because of the low risk, and because the efforts described above have not revealed any past or present instances of slavery or human trafficking in our supply chain, GHX has not adopted specific performance indicators on this issue. 

Adopted by the Board of Managers November 27, 2017