Introduction
SQEPtech considers modern slavery and human trafficking to be crimes and violations of fundamental human rights. They can take various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which involve depriving a person of their liberty 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 everyone who works for SQEPtech or on our behalf, in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns and agents. It also applies to our contractors, external consultants, agencies, third-party representatives, suppliers and business partners.
This statement sets out SQEPtech Limited's commitment to preventing slavery and human trafficking in our business activities, and the steps we have put in place to make sure there is none in our own business and supply chains. Everyone who works for SQEPtech has a duty to be alert to risks, however small. Staff are expected to report their concerns, and management to act on them.
SQEPtech will act with integrity in all its business dealings and relationships. This includes a transparent approach to tackling modern slavery and human trafficking, making sure appropriate controls are in place and in use.
Policy scope
SQEPtech is committed to ensuring there is no modern slavery or human trafficking in its business or supply chains. This statement affirms our intention to act ethically in our business relationships. The policies below set out how we identify modern slavery risks and the steps we take to prevent slavery and human trafficking in our operations.
Organisational structure and supply chains
SQEPtech is a provider of implementation services for Cornerstone OnDemand and of SaaS solutions and software. We are based in the UK and comply with UK legislation. Our business activities cover:
- software and infrastructure development of SQEPtech solutions and products;
- a UK payroll solution, white-labelled and supplied by our partners;
- technical services as an integration partner.
There is a risk that modern slavery and human trafficking exists within supply chains and in any activities SQEPtech outsources, and this risk may vary by jurisdiction. Our supply chain is mainly in Europe and North America, where legal safeguards exist. Those safeguards do not remove the risk.
Our Supplier Code of Conduct requires suppliers to agree to SQEPtech's position on modern slavery and human trafficking, which they can review on our website.
Responsibilities
The Senior Management Team, led by the CEO, is responsible for SQEPtech's Modern Slavery and Human Trafficking policy, including:
- setting policy;
- making sure systems are in place to manage and monitor compliance;
- making sure the policy is communicated and understood;
- reviewing and updating the policy periodically.
All SQEPtech staff and suppliers must comply with this policy.
Training
To make sure all staff understand the risks of modern slavery and human trafficking, they must read and sign off their acceptance of the relevant training.
Due diligence processes
SQEPtech carries out due diligence when taking on new suppliers and when regularly reviewing existing ones. This includes building and maintaining long-standing relationships with suppliers, making our expectations clear, evaluating the modern slavery and human trafficking risks for each supplier, and imposing sanctions on suppliers that fail to improve in line with an action plan we provide, up to and including ending the relationship.
Reporting
SQEPtech staff must report any instance or suspicion of modern slavery or human trafficking to the management team as soon as possible. Suppliers must report any instance or suspicion to their SQEPtech account manager or the CEO as soon as possible.
Policy breaches
Any SQEPtech employee who breaches this policy may face disciplinary action. Depending on the nature of the breach, this may be treated as gross misconduct and may result in dismissal. Depending on the nature of a supplier's breach, SQEPtech may work with the supplier to resolve the issue, but any supplier who breaches this policy may have its relationship with SQEPtech ended.
Monitoring
SQEPtech makes sure slavery and human trafficking is not taking place in any part of its business or supply chains by:
- requiring all relevant staff to complete modern slavery training every year;
- including modern slavery in staff induction training;
- having whistleblowing mechanisms in place;
- requiring all employees and suppliers to sign this policy to certify they will comply with the UK Modern Slavery Act.
This statement is reviewed and updated as necessary, at least once a year. The Directors endorse this statement and are fully committed to its implementation.
Approved and authorised by the CEO, SQEPtech Ltd.