Delivery Without
Compromise

QOB Modern Slavery Policy

SCOPE

This policy outlines the steps QOB Interiors Ltd have taken as an organisation to assess our operations and supply chains and mitigate any risk of slavery and human trafficking.

At QOB Interiors Ltd, we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in this policy. This policy sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking during the financial year 2020.

QOB Interiors Ltd are committed to conducting business ethically and responsibly and fully support the aims of the Modern Slavery Act 2015 and associated standards such as the UN Guiding Principles on Business and Human Rights. We are committed to tackling slavery and human trafficking wherever we can fulfilling our own responsibilities in the global effort to eliminate exploitation and abuse in the workplace. Slavery and Human Trafficking is an infringement on fundamental human rights and so we work with the highest ethical principles in mind, valuing integrity and transparency in everything we do.

DEFINITION

Modern slavery is defined as the recruitment, movement, harbouring or receiving of children, women or men through the use of force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation. It is a crime under the Modern Slavery Act 2015 and includes holding a person in a position of slavery, servitude forced or compulsory labour, or facilitating their travel with the intention of exploiting them soon after 14.

OUR BUSINESS

QOB Interiors Ltd are an interior fit-out, refurbishment and construction services main contractor where our supply chain is comprised of contractors, suppliers, producers of materials and manufacturers of a variety of mechanical, electrical and other products used in construction processes.

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier's reputation, respect for the law, compliance with health, safety and environmental standards, and references.

RISK ASSESSMENT

The Global Slavery Index presents significant evidence that highlights the risk that labour standards issues could be present in construction and property supply chains, in the production of construction materials, delivery of construction activities and through the provision of professional services equipment such as laptops and phones. To identify and mitigate the risks of slavery and human trafficking, QOB Interiors Ltd takes the following focussed approach to the procurement of labour, goods and services:

• Identification of issues and risks

• Collaboration with our clients, peers and suppliers

• Clear definition and contractual communication of our expectations

• Review and assessment of supplier compliance

• The resolution of challenges through training and supplier development.

SUPPLY CHAIN DUE DILLIGENCE

QOB Interiors use Constructionline and other prequalification tools to assess compliance of contractors and suppliers based in the UK. These tools assess our supply chain against labour standards, health and safety, environmental and business ethics criteria identifying issues and risks. Where issues are identified, we will work with our supply chain to seek resolution through training and development. If the issue is deemed serious and/or is not capable of remediation, we will remove the supplier from our database until the issue is fully resolved.

We require all suppliers to attest that:

• They don't use any form of forced, compulsory or slave labour

• Their employees work voluntarily and are entitled to leave work

• They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment

• They don't require employees to post a deposit/bond and don't withhold their salaries for any reasons

• They don't require employees to surrender their passports or work permits as a condition of employment

AWARENESS

QOB Interiors Ltd has raised awareness of modern slavery issues by putting up posters across our sites and sending an email that is focused specifically on modern slavery to all our staff, which explains:

• Our commitment in the fight against modern slavery

• Red flags for potential cases of slavery or human trafficking

• How employees should report suspicions of modern slavery

TRAINING

All employees who have direct responsibility for supply chain management receive training on how to mitigate slavery and human trafficking

REPORTING CONCERNS

Where employees have concerns around issues of forced labour, human rights, recruitment practices or exploitation, they are encouraged and expected to report concerns to their line manager who will investigate and report their findings to our company directors.

REVIEW

We will continue to review and, evolve our approach as we gain further understanding of the risks presented by our business activities and suppliers and in line with guidance published by the UK Government.

Steven Argent

Managing Director

Date: 11th August 2020