Slavery Statement

Our Code of Conduct make clear that we expect our own people and everyone employed by our suppliers, whether permanent or temporary, to be treated with respect and dignity at work and we believe employment should always be chosen. There must be no forced, bonded or involuntary labour. Employees must not be required to lodge monies or identity papers to be able to work and must be free to leave employment after the giving of reasonable notice.

We are publishing this statement to explain the actions we have taken to mitigate modern slavery within our supply chain and the steps we intend to take over the coming year.

NordicQ  (“the Company”) is a specialist Software Testing Consultancy and the main trading company of NordicQ group who trade under the core brands of NordicQ.

As a provider of testing services we consider our supply chain to be relatively simple in comparison to many other industries.

We work with a small range of suppliers who provide services across a number of different categories in the Financial sector, such as Banking, Insurance, Asset Management, pension funds and other financial services alike and all seperate companies which have a need for testing Services. For the IT sector, our division provides services for the same categories and other services companies in the fields of IT.  Therefore, we have close relationships with our suppliers and good visibility of our supply chain.

We have evaluated the nature and extent of the Company’s exposure to the risk of modern slavery occurring in its supply chain. As our core business is focused on the provision of recruitment services in respect of professionals, office and administrative workers (rather than in relation to agriculture, retail or manufacturing, which are sectors we perceive to present a higher risk of labor exploitation and modern slavery), we do not consider that we operate in a particularly high risk sector. That said, when appraising our supply chain, a risk based approach has been developed, focusing on:

a)    products we buy that are imported from countries identified as having a high risk of Modern Slavery; and
b)    services we consume across industries where modern slavery is typically more prevalent.

In terms of the products we buy, we have referred to the Global Slavery Index’s list of products with identified risk of forced labor by source countries .  The only risk area identified relevant to the Company was in relation to Electronics – laptops, computers and mobile phones.  The Company, like with many other corporate organizations, consumes products in these areas from globally recognized firms who we require to have established modern slavery policies and practices in place, and we will continue to monitor their activities.

In terms of the services we consume, our risk assessments have determined that cleaning and recycling/waste disposal services represents the only service line which carries a higher risk of modern slavery.

This evaluation process across both categories continues on bi-annual basis.

Our employees are required to comply with our Employee Code of Conduct and our suppliers with our Supplier Code of Conduct.

These policies reflect our commitment to acting ethically and with integrity in our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place in our business and supply chain.

Our Own Business
The Company prohibits the use of all forms of forced labor and any form of human trafficking as set out in the Employee Code of Conduct. We have a number of procedures in place in relation to our employees to proactively manage any risk, including robust recruitment processes in line with employment laws and a confidential third party operated “Speak-Up” helpline operating across our business which employees and third party workers are encouraged to use to report any concerns.

As part of our own business we supply temporary personnel to a number of clients. We take our obligations seriously in this respect and have well established and audited procedures to ensure that those temporary workers are protected from the risks of modern slavery. We ensure that:

• temporary workers have a right to work for the duration of their assignment. This involves asking the individual directly to view their relevant identity documentation. A delay in providing  proof of identity and/or associated right to work documentation might indicate a modern slavery issue and would be escalated appropriately;
• we take relevant references to ensure the individual is hired in a role that they have both the qualifications and experience to undertake;
• we carry out detailed background checks and ensure all contracts comply with all legal requirements regarding workers’ rights;
• where we provide payroll services as required by our own clients, we check that such temporary personnel have a bank account in their own name into which their remuneration is paid;
• where we are responsible for such temporary personnel while they are on assignment on our client’s premises, they are  always free to leave their assignment; and
• temporary workers receive compliant pay as determined by the Agency Workers Regulations 2011.

In addition, all employees, through the Employee Code of Conduct, are made aware of the requirement for employees to support and uphold human rights principles and know that the Company will not tolerate, engage in or support the use of, forced labor.

We map and risk assess our tier 1 suppliers who provide goods and services directly to our business. We include due diligence queries in RFP processes to identify our potential suppliers’ approach to modern slavery and these assist in our determination of whether the supplier should be considered a high risk supplier. A high risk supplier is sent a questionnaire so we can further assess their approach to the issue of modern slavery.

We place an obligation on suppliers to comply with the Modern Slavery Act 2015 and where appropriate also include rights of audit to help us identify unethical practices.  If we were to find evidence that one of our suppliers has failed to comply with the Modern Slavery Act 2015 then we would require the relevant supplier to remedy such non-compliance and we would terminate our relationship should we see no improvement in the way their business is conducted.

This approach is designed to:

• identify and assess potential risk areas in our supply chain;
• mitigate the risk of slavery and human trafficking occurring in the supply chain;
• monitor potential risk areas in the supply chain; and
• provide adequate protection to whistle blowers.

Other instruments that we can use identifying risk are including (but not limited to):

• Auditing
• Whistleblowing
• Breach monitoring

We report to the Company’s Director on modern slavery risks.