Introduction

The SQR Group of Companies (‘SQR’), which includes SQRx Ltd (UK) and SQR Group Ltd (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 Ltd, 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 Ltd is wholly owned by SQRx Ltd, a company in the UK, with company number 15550944.

Our business

SQR is a government-backed, award-winning leader in secure and compliant digital identity verification. Our reusable Digital ID and eKYC Compliance Dashboard eliminate repetitive KYC checks, reduce manual compliance work, cuts costs, and accelerates onboarding. With advanced fraud prevention, ongoing monitoring, and seamless API integration, we provide businesses, governments, and regulated industries with a future-proof solution for identity verification. Accredited by the UK Government Trust Framework, SQR ensures security, efficiency, and inclusivity while giving users full control over their sensitive data.

With a mission to make the world a safer place to be, do and transact; we believe that starts with trusting who you are dealing with AND consent. With security, efficiency and inclusivity at the heart of what we do, SQR enables individuals to efficiently prove they are who they  say they are, whilst allowing organisations to have improved governance and compliance controls.

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 is 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 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 a number of internal policies, which support our position in place. This Modern Slavery statement, our Anti-Bribery & Corruption and Whistleblowing Policies are all readily available to all team members via SQR’s internal communications platform. 

As part of SQR’s whistleblowing processes, we encourage team members to raise any concerns and provide clear reporting options. 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 share short annual training modules on Modern Slavery with references to 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. 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 12 months prior to publication of this version of the Modern Slavery Statement, we have:

• Ensured all new and existing team members continued awareness of the issues via updated training and onboarding processes, ensuring that all employees understand the risks and reporting mechanisms;
• Continued to conduct 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
• Continued to include obligations regarding compliance with Modern Slavery legislation in our standard Terms and Conditions for suppliers, making it a mandatory part of all new contracts.

• Adhered to the established procurement strategy for SQR, which better controls who we spend our money with and the due diligence required prior to placing orders;
• Reminded staff that the  whistleblowing mechanism provides a confidential and accessible way for employees to report any suspicions of unethical practices and modern slavery concerns;
• Enhanced training programs by incorporating case studies, and e-learning modules with testing 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.