Qlearsite Modern Slavery Policy

1. Policy Statement

1. This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that Qlearsite has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
2. Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Qlearsite has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within our organisation or our supply chain.

2. Our Organisation

Qlearsite is a technology company employing a workforce with diverse skill sets. Its core business is the supply of a suite of HR software solutions including survey and data analytics technologies.  We are based in the UK and have clients globally.

3. Our Supply Chain

1. Qlearsite works with a number of suppliers, ranging from those providing professional services to IT and administrative services
2. Qlearsite takes the selection of its suppliers very seriously. Where as part of our contract with tendered suppliers and as part of ur due diligence we require that:

• (For UK based suppliers) They pay their employees at least the national minimum wage
• (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations
• We will terminate the contract at any time should any instances of modern slavery come to light.

4. Policies

1.  We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

• Anti-slavery Policy: This policy sets out the organisation’s stance on modern slavery and explains where employees can go for help or raise concerns.
• Recruitment Policy: We operate a robust recruitment policy, including conducting eligibility to work in the UK and background employment checks.
• Whistleblowing policy: We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
• Code of Business Conduct: This Code explains the manner in which we behave as an organisation and how we expect our employees, volunteers and suppliers to act.

5. Our Continued Commitment

1. We are committed to continuing our work to review and monitor our policies, procedures, agreements and training, and in doing all that we can to make sure that contributing to modern slavery has no place in Qlearsite.
2. We will continue to review, update and invest in policies, training and procedures that will promote knowledge as to the dangers of human trafficking and modern slavery.
3. We will continue to review and enhance our due diligence process for our suppliers and partners.
4. We will continue to invest in our reporting systems and improve our reporting process and ensure that employees and partners are able to report suspicions anonymously.
5. We will complete the implementation and training of our safeguarding policy and manual to all employees across Qlearsite.

Approval for this Statement

6.1 This statement was approved by the Qlearsite CEO.

Name: Alex Borekull

Date: 1 August 2019