Introduction

The SQR Group of Companies (‘[SQR’), which includes SQRx UK and SQR Isle of Man  make this  Modern Slavery Statement pursuant to section 54(1) of the UK Modern Slavery Act 2015 (the “Act”).  Whilst we do not yet meet the legal requirement for publication of an annual statement, 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 and 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 developing and monitoring  our business activities  and relationships  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 is the trading name of SQR Group, which is an Isle of Man Company, with offices in the Isle of Man, with company number 134592C It has no subsidiary companies.

SQR Group  is wholly owned by SQRx, a company in the UK, with company number 15550944.

Our business

SQR exists to build trust through verified identities in order to make the world a safer place and we do this by facilitating online environments, where everyone can transact with complete 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. 

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 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. Some of those affected are people hidden within the supply chains of legitimate industries. 

SQR are committed to acting with integrity and transparency in all our business dealings. We expect our suppliers, contractors, and business partners to adhere to the same high standards. We do not tolerate any form of modern slavery, including forced labour, child labour, or human trafficking, within our operations or supply chains. The company will not support or deal with any business knowingly involved in slavery or human trafficking.

Due diligence

SQR supplier and other third party relationship due diligence processes take account of  modern  slavery and human trafficking risk. As part of our commitment, we implement a robust due diligence process that includes:

• Conducting risk assessments of our supplier and understanding – as much as is possible – any further parties in the supply chain,  to identify areas where modern slavery risks may be present;
• contract terms which lay out our  our ethical standards, including provisions against modern slavery; and
• Regularly reviewing our procurement and contracting processes to mitigate the risk of modern slavery.

SQR’s 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 with both legal requirements and industry best practice. 

Our policies on slavery and human trafficking

The Board takes ultimate responsibility for ensuring we comply with our legal and ethical obligations. All managers 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 which support our position. This Modern Slavery statement,  our Anti-Bribery & Corruption and Whistleblowing Policies are readily available to all team members via SQR’s internal comms platform. 

As part of SQR’s whistleblowing processes, we encourage team members to raise any concerns and provide clear reporting options for the same. 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. From September, 2024, all staff are required to complete an annual modern slavery online training course and quiz to refresh their understanding and keep up to date with any changing legislation. It is imperative that all staff remain vigilant to the signs that can point towards modern slavery violations.

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. 

In the last 12 months prior to publication of this version of the Modern Slavery Statement, we have:

• Improved team member awareness on modern slavery through updated training and onboarding processes, ensuring that all employees understand the risks and reporting mechanisms;
• Conducted enhanced due diligence as part of the onboarding process of new suppliers, including more comprehensive background checks and risk assessments to identify any potential modern slavery risks; and
• Included strong obligations regarding compliance with Modern Slavery legislation in our standard Terms and Conditions for new suppliers, making it a mandatory part of all new contracts.

We will also continue to take the following steps within the next 12 months of this publication:

• 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;
• Reminding staff that the  whistleblowing mechanism provides  a confidential and accessible way for employees to report any suspicions of unethical practices and modern slavery concerns;
• Enhance training programs by incorporating case studies, expert-led workshops, and e-learning modules to deepen employee’s understanding of modern slavery; and
• Increase collaboration with industry bodies focused on combating modern slavery to stay informed on emerging risks and best practices.