Modern Slavery and Human Trafficking Statement
- 1 Policy Statement
- 2 Scope of the Policy
- 3 High risk activities
- 4 Responsibility for anti-slavery
- 5 Training
- 6 Policies
- 7 Performance Indicators
1. Policy Statement
1.1 This Modern Slavery and Human Trafficking Statement relates to actions and activities during the following financial periods:
- For QBS Technology Group Limited, the year ended 31 March 2023
- For QBS Software Limited, the year ended 31 March 2023.
1.2 The statement sets down the commitment of QBS Technology Group Limited and QBS Software Limited (together referred to as QBS) to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks and staff are expected to report their concerns in order for management to act upon them.
2. Scope of the Policy
2.1 This statement covers the business activities of QBS which are as follows:
- Providing representation services and fulfilment for leading software publishers and some hardware manufacturers;
- The sale and distribution of third-party computer software products;
- The design and development of software;
- Technical consultancy services; and
- Conducting computer training programmes.
2.2 QBS trades with third parties through QBS Software Limited, which is incorporated and resident in England and operates from premises in Wembley, Middlesex, Retford Nottinghamshire, Telford, Shropshire and Alderley Edge.
2.3 Most of QBS’s sales activities are undertaken with customers in the UK, though there is also significant trading from QBS’s UK premises with customers in the European Union and in many other countries in the World.
2.4 QBS sources the computer hardware and software products it distributes from over 2,000 active suppliers. Approximately one-third of these products are sourced from UK suppliers, approximately one-third from suppliers in the European Union, and approximately one-third from suppliers in numerous countries in other parts of the world. These suppliers are almost exclusively computer software publishers, OEM hardware manufacturers, or are themselves distributors of computer hardware and/or software.
2.5 The following is the process by which QBS assesses whether particular activities or countries are high risk in relation to modern slavery or human trafficking:
- QBS undertakes periodic reviews to assess whether particular activities or countries are high risk in relation to modern slavery or human trafficking by applying a methodology which is based around a supplier’s country of operation and their category of supply. If any higher risk suppliers are identified they are subjected to further inquiry and assessment; and
- Where QBS engages a new relationship supplier, there is a supplier onboarding process that, amongst other things, includes an assessment of any slavery or human trafficking risk and a request to confirm compliance with modern slavery legislation; and
- If any supplier is considered to be at risk in relation to possible slavery or human tracking, then QBS will either decline to trade with the supplier or will make further inquiry and or keep the supplier relationship under review.
3. High risk activities
3.1 QBS’s computer software products are highly technical in nature and their development and distribution by suppliers is considered by QBS to be a low-risk activity in relation to slavery or human trafficking risk.
3.2 Some of QBS’s computer hardware and peripheral/accessory products are manufactured in parts of the World where manufacturing costs are significantly lower than they would be in Europe. However, many of the suppliers are internationally recognised brands. QBS currently considers this part of its business to be a medium-risk activity in relation to slavery or human trafficking risk.
3.3 Whilst the situation is kept under continuous review, QBS does not currently consider any part of its business to be a high-risk activity in relation to slavery or human trafficking risk.
4. Responsibility for anti-slavery
4.1 Responsibility for QBS’s anti-slavery initiatives lies with its Head of Legal, Steve Turner, who is responsible for:
- Creating and reviewing policies. The process by which policies are developed is:
- Reviewing best practice and publications; and
- Seeking professional advice and/or guidance where required.
- Risk assessments: The process by which risk is assessed is a process of annual review.
- Due diligence: QBS undertakes due diligence when considering taking on new suppliers and regularly reviews its existing suppliers. QBS’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of business partners, evaluating the modern slavery and human trafficking risks of each new supplier and 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. Recently QBS has updated its vendor onboarding process to include additional compliance questions which require positive affirmation from suppliers that they are compliant with anti-slavery and human trafficking legislation.
5.1 QBS makes a copy of its anti-slavery policy available to all employees. Staff activity is closely managed by QBS’s senior management and further guidance in relation to anti-slavery and human trafficking awareness is given on-the-job.
6.1 QBS is committed to ensuring that there is no modern slavery or human trafficking in its business or our supply chains. This statement affirms QBS’s intention to act ethically in its business relationships.
6.2 The following policies set down QBS’s approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
- Whistleblowing policy - QBS encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.
- Code of Ethics - this sets out the actions and behaviour expected of employees when representing QBS.
- Corporate Responsibility Charter – this is available on QBS’s websites and summarises the responsibilities of employees and third parties.
7. Performance Indicators
7.1 As stated above, compliance with is reviewed by the Head of Legal periodically.
7.2 This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as required by law for each of QBS’s financial years and additionally as necessary. QBS’s board and senior management team endorses this policy statement and is fully committed to its implementation.
This Modern Slavery and Human Trafficking Statement has been approved and authorised by:
Name: G D Stevinson
Position: Chief Executive Officer
Date: 30 September 2023