Modern Slavery Policy
Introduction
Although SQR are not legally obliged at this point to set out a Modern Slavery Policy pursuant to section 54(1) of the UK Modern Slavery Act 2015 (the “Act”), we have nevertheless outlined the steps SQR has taken to ensure that slavery, human trafficking and child labour is not taking place in our supply chain or in any part of our business. We recognise that all businesses have a key role to play in preventing all types of modern slavery in their own business and supply chains through the promotion of ethical business practices and policies.
We are continually considering ways to maximise the positive societal contributions of both our own business and those of the companies we work with.
At SQR, we are committed to improving our practices to ensure that slavery and human trafficking are not taking place in any part of our business or supply chain. We believe the risk of modern slavery in our supply chain is low, however, we are not complacent and will continue to focus on improving our procedures and policies. We expect the same commitment from our suppliers, contractors and business partners.
SQRs organisational structure
SQR Group is an Isle of Man Company, with offices in the Isle of Man.
Our business
SQR exists to build trust in the digital world and we do this by facilitating online environments, where everyone can transact with complete and unconditional confidence. We believe it is our ability to establish trust between businesses and their customers that places us at the heart of the global digital economy.
To this end, we provide a number of business solutions aimed at informing decisions about customers in key areas:
- Location – facilitating the registration and validation of identity data, such as name, address and contact information, quickly and with minimum impact on the customer experience. SQR’s technology confirms and locates the people our clients need to connect with.
- Identity – providing more innovative ways of confirming identity than simply relying on credit data. Our solution is designed to help prevent fraud and avoid regulatory fines, with our powerful identity verification process configured to carry out a wide range of functions - including Know Your Customer (KYC) Checks, Anti Money Laundering (AML) Checks, fraud protection and age verification checks.
- Fraud Detection & Compliance – fraud prevention solutions not only check new customer details in real time as they register, but monitor and detect application and transaction fraud on an ongoing basis. We enable businesses to stay vigilant amid the acceleration of digital adoption and financial crime. Our end-to-end fraud and compliance solutions provide multi-layered protection against synthetic identity fraud, first-party fraud detection, account takeovers, social engineering, money mule crimes, money laundering, terrorist financing and more.
Supply chains
Although slavery is illegal in every country in the modern world, it unfortunately still exists and is a brutal form of organised crime, whereby people are forced to work against their will under the threat of some form of punishment or detriment. Most of these people are in the supply chains of legitimate industries.
Risk in the supply chain
Imported goods from sources outside the UK and EU are potentially more at risk for slavery/human trafficking issues. The level of management control required for these sources will be continually monitored. The company will not support or deal with any business knowingly involved in slavery or human trafficking and the company will continue to protect whistleblowers.
Due diligence
As part of our due diligence processes into slavery and human trafficking, our supply chain approval process incorporates a review of the controls undertaken by the supplier or partner.
SQR minimum expectations of its supply chain:
- No forced, bonded or involuntary prison labour or child labour;
- Workers have the right to join or form trade unions and rights for free association and bargaining;
- Working conditions are clean, safe and hygienic;
- Working hours comply with national laws and benchmark industry standards; and
- Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation are prohibited.
As we develop our thinking around modern slavery, we will continue to update our procurement and governance processes to ensure compliance to both legal requirements and industry best practice. This includes the ongoing development and improvement of our formal supply chain due diligence process.
Our policies on slavery and human trafficking
The Board takes ultimate responsibility for ensuring we comply with our legal and ethical obligations. All Executive Team members are responsible for ensuring their teams understand and comply with the requirements and know how to raise areas of concern. We are committed to acting ethically and with integrity in all of our business relationships and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business or supply chains.
As part of our commitment to combating modern slavery, SQR has in place a number of internal policies on matters such as Anti-Bribery & Corruption and Whistleblowing which are readily available to all team members via SQR’s internal intranet.
As part of SQR’s whistleblowing processes, we encourage team members to raise any concerns and provide clear reporting lines. At the time of publication, no concerns regarding slavery or human trafficking have been raised.
Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we circulate and share our Modern Slavery statement with team members annually. In addition, all new starters are required to review and confirm their understanding of our Modern Slavery statement as part of their online induction process.
Effectiveness
We recognise that the fight against modern slavery is not static. Therefore, to improve our mitigation and to ensure we can demonstrate our continued commitment to eradicating slavery and human trafficking from our supply chains, we will continue to monitor and modify our approach.
We will also continue to take the following steps within the next 12 months of this publication:
- Improve team member awareness on modern slavery through updated training.
- The creation of a procurement strategy for SQR, that will introduce enhanced processes to better control who we spend our money with and the due diligence required prior to placing orders.
- Ensure suppliers support SQR’s principals as set out in its Modern Slavery Statement and that they comply with applicable legislation and regulatory requirements.
- As part of the onboarding process of new suppliers, our standard Terms and Conditions include strong obligations regarding compliance with Modern Slavery legislation.
- Instances of non-compliance are assessed on a case-by-case basis and any remedial actions are tailored appropriately.
The statement has been approved by the Board of SQR Group Plc on 28th March 2023 and signed by Michael Dodd, Founder of SQR Group.
