Modern Slavery and Human Trafficking Statement This statement is made pursuant to Section 54(1) of the UK Modern Slavery Act 2015. It outlines the steps that TESTQ Technologies Limited ("TESTQ", "we", "our" or "the Company") has taken during the financial year to prevent modern slavery and human trafficking in our operations and supply chains. TESTQ is committed to acting ethically, with integrity, and to ensuring that slavery and human trafficking have no place in our business or our supply chains. 1. Organisational Structure, Business, and Supply Chains TESTQ Technologies Limited is a privately-owned IT services and consulting company headquartered in the United Kingdom. We provide specialised solutions in digital marketing, IT Services and Solutions, Offshore Business Processing, Testing Services and recruitment services, supporting both public and private sector clients across the UK and Europe. Our supply chains include a range of professional service providers, technology partners, recruitment agencies, independent contractors, umbrella companies, and software vendors. While our direct operations are primarily based in low-risk regions, we recognise the potential risks within extended supply chains, particularly where services are outsourced or sourced internationally. 2. Policies Relating to Slavery and Human Trafficking TESTQ maintains a zero-tolerance approach to modern slavery and human trafficking. Our policies and procedures reflect our commitment to conducting business ethically and ensuring transparency in our own operations and our supply chains. Key policies include: • Modern Slavery and Human Trafficking Policy: This policy explicitly prohibits all forms of forced labour, slavery, servitude, and human trafficking. It sets out the responsibilities of all employees and suppliers to identify and address any indicators of such practices.
Code of Conduct: This policy establishes mandatory ethical and labour standards, including respect for human rights, applicable to all employees, contractors, and third-party suppliers. It reinforces TESTQ’s expectations for integrity, fairness, and legal compliance in all engagements. • Whistleblowing Policy: This policy enables employees, and suppliers to safely report any suspicions or concerns related to unethical behaviour, including modern slavery or human rights violations. 3. Due Diligence Processes As part of its due diligence processes in relation to slavery and human trafficking in its business and supply chains, TESTQ Technologies Limited undertakes rigorous and proactive measures to identify, assess, and mitigate the risk of modern slavery in all areas of its operations. Our approach includes: • Supplier Risk Assessments: We evaluate all suppliers based on geographic location, industry-specific risk factors, and the nature of the services or goods provided, ensuring we prioritise oversight for higher-risk relationships. • Onboarding Processes: All new suppliers and partners are required to formally confirm adherence to the UK Modern Slavery Act 2015. This is done through contractual obligations and compliance declarations, ensuring alignment with our anti-slavery standards from the outset. • Audits and Monitoring: We perform regular reviews and spot audits of suppliers as appropriate, especially where services are outsourced. These activities help verify ongoing compliance with our anti-slavery and ethical sourcing policies. • Employee Screening: All directly employed and contracted personnel undergo right-to-work verification checks and are engaged only under fair, lawful, and transparent employment terms. This reduces the risk of exploitation within our direct workforce. 4. Risk Assessment and Risk Management The parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk, TESTQ Technologies Limited acknowledges that certain areas of our business and supply chains present higher vulnerability to modern slavery risks. We have identified the following areas as posing increased exposure:
Labour supply chains: Especially recruitment agencies and umbrella companies engaged in providing contingent or subcontracted labour. These intermediaries may operate in ways that obscure the true nature of working conditions, particularly in high-volume or fast-turnaround engagements. • Technology supply chains: Involving international software development and IT support services. To address these risks, we have taken proactive steps, including: • Prioritising suppliers from low-risk jurisdictions. • Integrating modern slavery risk assessments into procurement and supplier management processes. • Requiring suppliers to adopt their own anti-slavery policies and provide transparency into their supply chains. 5. Measuring Effectiveness We measure our effectiveness in combating modern slavery and human trafficking through the following indicators: • Supplier Compliance: Percentage of suppliers who have formally committed to our Anti-Slavery Policy. • Incident Reporting: Monitoring reports or disclosures related to slavery or human trafficking — to date, there have been no reported incidents. • Training Participation: Completion rates of mandatory staff training on modern slavery and ethical labour practices. • Annual Policy Review: Regular updates to ensure that policies remain effective and aligned with best practices. These performance indicators enable us to continuously monitor and enhance our approach to eliminating modern slavery risks. 6. Training and Capacity Building To strengthen our efforts, we provide targeted training to relevant staff to ensure they are aware of the risks associated with modern slavery and know how to identify and report potential issues. • Mandatory Training: All employees involved in procurement, recruitment, and supplier management complete mandatory modern slavery awareness training.
Capacity Building: Management and leadership teams receive additional training on ethical supply chain management and risk mitigation. • Continuous Awareness: We promote ongoing education on ethical labour practices and update training content to reflect new threats and regulatory updates. 7. Reporting and Whistleblowing: • All employees and stakeholders are encouraged to report any concerns or suspicions related to modern slavery. • Reports can be sent anonymously to testq@testqtech.com. • We ensure protection against retaliation from whistleblowers.