Modern slavery policy statement

Modern day slavery (including slavery, servitude, forced labour and human trafficking) is a growing and pervasive problem, impacting every level of society. The investor services industry is not a high risk sector for modern slavery, however IQ-EQ understands that no business or sector can be considered immune. IQ-EQ is committed to ensuring that slavery, human trafficking and forced labour have no place in or around our business and has therefore put processes/policies in place to strengthen our approach to tackling any risk.

Our 2022 Modern slavery statement

IQ-EQ policy

IQ-EQ understands that people lie at the heart of this legislation. Our business is built around people – customers, colleagues and communities. We have a responsibility to respect the human rights of our colleagues, customers, the communities we operate in and the people who work throughout our supply chain, and we have an opportunity to make a difference.

IQ-EQ does not tolerate slavery, human trafficking, forced labour, child labour or child exploitation. We have implemented a number of policies which allow us to manage human rights both within and out with our business including our code of conduct.

Procedures adopted to assess and manage slavery and human trafficking risk

As an investor services organisation, we believe the risk of modern slavery within our own business to be low. We recognise, however, that through our supply chain we could be indirectly exposed to the risk of modern slavery and human trafficking.

We have sought to identify processes and supply chains where workers are more vulnerable to abuses like slavery. As part of this process we considered:

• The types of service provided by our suppliers.
• The type of labour used, for example seasonal, permanent or agency.
• Whether there are any known issues in the country of origin of our suppliers.
• Whether there are any issues in the country where services are provided, which may feature further down the supply chain for example in relation to the sourcing of materials and components.

This process identified certain services such as catering and cleaning as potentially being more vulnerable to labour abuse. IQ-EQ has therefore introduced a number of procedures to ensure that modern slavery does not occur in our business or supply chains:

Supply Chain

While investor services is not a high risk sector for modern slavery, we have identified that catering and cleaning services may be more vulnerable to labour abuse. We have therefore taken steps to mitigate any risks, including asking our suppliers to confirm that they are fully aware of, and committed to, the objectives and requirements to prevent Modern Slavery. We also asked them to provide assurance that they were developing appropriate policies for their business as well as their supply chain (see our supplier code of conduct here).

Where third parties are identified as being key suppliers to IQ-EQ, a full due diligence assessment is also carried out before the supplier is engaged. This assessment covers a range of topics including regulatory & legal compliance, HR and integrity. In addition, suppliers are asked to attest to their compliance with the supplier code of conduct as part of the ongoing Supplier Assurance activity. This includes a review of their position on modern slavery & human trafficking.

Recruitment and Employment

IQ-EQ has appropriate recruitment processes and procedures in place, including conducting eligibility to work in the jurisdiction checks for all employees, to safeguard against human trafficking or forced labour. The majority of our colleagues are full time and all colleagues have Terms and Conditions which are regularly reviewed in line with employment law and best practice.

In addition, IQ-EQ only uses reputable employment agencies and we always verify the practices of new agencies before engaging any staff. Recruitment agencies are risk assessed by our HR Team. We have long-standing relationships with the majority of these agencies and we are assured of their practices from previous experience and their reputation in the marketplace. If we engage any temporary staff from agencies, they are always thoroughly checked prior to their appointment which safe guards against modern slavery.

Education and Ethical Standards

In addition to having suitable policies in place, IQ-EQ understands that a key part of our commitment to combat modern slavery is to ensure all colleagues understand what modern slavery is and comply with the highest ethical standards and integrity. We embed this in our business via the IQ-EQ Values and our Code of Conduct.