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Modern Slavery and Human Trafficking Statement

1. Introduction

SQEPtech consider that modern slavery and human trafficking are crimes and violations of fundamental human rights. These may take various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking all of which include the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

SQEPtech has a zero-tolerance approach to modern slavery and human trafficking within its business and supply chains.

This policy applies to all persons who work for SQEPtech or on our behalf, in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns and agents. This policy also applies to our contractors, external consultants, agencies, third-party representatives, and suppliers and business partners.

This Modern Slavery and Human Trafficking Statement sets down SQEPtech Limited’s commitment to preventing slavery and human trafficking in our business activities and the steps that have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. All those who work for SQEPtech have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.

SQEPtech is will act with integrity in all its business dealings and all its relationships. This includes a transparent approach to tacking modern slavery and human trafficking, ensuring that appropriate controls are in place and in use.

2. Policy Scope

SQEPtech is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.

The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations.

3. Organisational structure and supply chains

SQEPtech is a global provider of implementation services for Cornerstone OnDemand and of innovative SaaS solutions and software. SQEPtech is based in the UK and complies with UK legislation. For more information about who we are what we do please visit our website https://sqeptech-dotcom-appservice.azurewebsites.net/index.php/about-us/. Business activities cover the provision of

  • Software & infrastructure development of SQEPtech solutions and products.
  • UK payroll solution white labelling supplied by our partners.
  • Technical services as an integration partner.

There is risk that modern slavery and human trafficking exists within supply chains and any activities SQEPtech outsources. This risk may vary by legal jurisdiction. SQEPtech’s supply chain is primarily concentrated in Europe and North America, where there are legal safeguards in existence. However, the existence of legal safeguards does not exclude or avoid the risk.

The Supplier Code of Conduct requires suppliers to agree on SQEPtech’s position on modern slavery and human trafficking available on SQEPtech’s website.

4. Responsibilities

Responsibility for SQEPtech’s modern slavery and human trafficking policy is as follows:

The senior management team, led by the CEO, is responsible for

  • setting policy;
  • ensuring that systems are in place to manage and monitor compliance with this policy;
  • ensuring this policy is communicated and understood;
  • periodic review of this policy and updating where necessary.

All SQEPtech workers must comply with this policy.

All SQEPtech suppliers must comply with this policy.

5. Training

To ensure a good understanding of the risks of modern slavery and human trafficking all staff must to read and sign off the acceptance of relevant training.

6. Due Diligence Processes for Slavery and Human Trafficking

SQEPtech undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The due diligence process includes building and maintaining long-standing relationship with suppliers, making clear our expectations of our business partners, evaluating the modern slavery and human trafficking risks for each supplier, invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.

7. Reporting

SQEPtech workers must report any incidence of modern slavery or human trafficking, or suspicion of modern slavery or human trafficking, at the earliest opportunity, to the management team.

Suppliers must report any incidence of modern slavery or human trafficking, or suspicion of modern slavery or human trafficking, at the earliest opportunity, to the SQEPtech account manager or CEO.

8. Policy breaches

Any SQEPtech employee who breaches this policy may face disciplinary action. Dependent upon the nature of the breach, this may include gross misconduct and may result in dismissal.

Dependent upon the nature of the breach SQEPtech may opt to work with the supplier to resolve the issue. However, any supplier who breaches this policy may have its relationship with SQEPtech terminated.

9. Monitoring

SQEPtech uses the monitors how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains including requiring all relevant staff to have completed training on modern slavery on a yearly basis.

  • Training on modern slavery
  • Promoting on-boarding staff training on modern slavery
  • Whistleblowing mechanism in place
  • Ensuring all employees and suppliers sign this policy to certify they will comply with the UK’s Modern Slavery Act.

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary, and at minimum of a yearly review. The Directors endorse this policy statement and is fully committed to its implementation.