Introduction

This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year 1st January to 31st December 2023.

The statement sets down Qualco UK’s commitment 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, however small.  Staff are expected to report their concerns and management to act upon them.

Organisational structure and supply chains

This statement covers the business activities of Qualco UK which are as follows:

Qualco UK Limited (“the Company”) is a technology company focused on the collections and recoveries industry. Using data and analytics we help our clients optimise their operations and better understand their customer’s needs. We are a private limited company operating solely in the UK, working with a select group of partners who provide data analytics and services related to debt collection and recovery.

Risk assessment is carried out on the Company activities and to date no activities are high risk and the Company does not operate out of or have any connection with countries which are high risk in relation to modern slavery or human trafficking.

Responsibility for the Company’s anti-slavery initiatives is as follows:

1.1 The Business Support Manager, working with the Head of Risk & Compliance is responsible for creating and reviewing policies. The process by which policies are developed is looking at best practice and adapting to the needs of the Company, ensuring compliance with any legislative updates.

1.2 The Risk & Compliance function is responsible for risk assessments in respect of human rights and modern slavery by a process of due diligence completed on partners and suppliers.

1.3 The Head of Risk & Compliance is responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking with the Managing Director taking ultimate responsibility.

Training

To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company requires staff to complete annual mandatory training.

Policies

The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.

The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations. The Policies are located in the Company shared network drive and can be accessed by all employees:

2.1 Whistleblowing Policy & Procedure: The Company encourages all its employees, clients and other business partners to report any concerns related to its direct activities or its supply chains.

2.2 Company Code of Conduct & Ethics - The Code of Conduct sets down the actions and behaviour expected of employees when representing the Company.

2.3 Corporate Social Responsibility Statement - The Company’s CSR statement summarises how we work responsibly with suppliers and local communities.

Due Diligence Processes for Slavery and Human Trafficking

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes:

• building long-standing relationships with suppliers who have values which match those of Qualco
• making clear our expectations of business partners and evaluating the modern slavery and human trafficking risks of each new supplier and
• if necessary, 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

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. The Senior Leadership team endorses this policy statement and is fully committed to its implementation.

This statement has been approved & authorised by:

Name: Christian Jacob
Managing Director
Date: January 2024