Anti-Slavery and Human Trafficking Statement

IQSA Group Anti-Slavery and Human Trafficking Statement

Introduction

IQSA Services Limited (a company incorporated in England and Wales with company number 09857188) is publishing this statement in compliance with section 54 (1) of the Modern Slavery Act 2015 (the “Act”). It details the steps taken by the corporate group comprising IQSA Holdco Limited (a company incorporated in Jersey with company number 131195) and subsidiary undertakings (the “Group”), to assist in the prevention of modern slavery and human trafficking in any part of the Group’s business and supply chain during the financial year ending 30 September 2022. This statement applies to all members of the Group.

As set out in our Modern Slavery Policy and Code of Ethics, we are fundamentally opposed to the abuse of human rights and will not tolerate or condone this within any part of our business or supply chain. We have zero tolerance to slavery and human trafficking and we expect those in our supply chain to comply with our values. As an organisation that has people and service at the heart of its business model, the preservation of human rights is key to how we do business.

iQ Student Accommodation is one of the largest providers of student accommodation in the UK. It has over 32,000 beds under management at 78 sites across the UK.

In addition to letting to students directly, the Group works in conjunction with some of the UK’s leading universities for the provision of accommodation directly to their students under a process of nomination or lease. The Group also owns a hotel.

Speak Up Policy and Training

The Group’s Speak Up Policy sets out the Group’s commitments to conducting business with fairness, integrity and respect and supporting any person working for or with iQ, including those employed in our supply chain, who raise concerns about possible misconduct. The Group has a confidential helpline in support of its Speak Up policy where members of staff can raise concerns over any wrongdoing which extends to human rights violations and modern slavery. Reports are treated in confidence and are always fully investigated at executive level.

The policy is supported by an e-learning training module which provides staff with information about modern slavery and how to spot the signs as well as providing advice on what they should do if they have concerns. All new joiners to the organisation are required to complete the modern slavery e-learning training module within 6 months of joining the organisation and all employees are required to refresh their modern slavery training every 2 years.

Assessment of Risk in the Supply Chain

Our Procurement Department has identified the following categories of supplier where we believe there is a greater risk of modern slavery. These types of business tend to pay lower wages and rely on labour from outside the country to undertake their business:

• Cleaning;
• Security;
• Sub-contractors for construction activities;
• Grounds Maintenance services;
• Overseas companies supplying outsourced business processing services; and
• Products typically manufactured in developing countries, such as furniture or textiles.

Steps the Group has taken to prevent modern slavery in our supply chain

The Group has continued to improve its supplier management processes by enhancing its onboarding processes and ensuring that more suppliers are contracting on the Group’s standard form of supplier contract.

The Group’s supplier onboarding procedures include questions about modern slavery as part of the suite of checks undertaken for new suppliers. Our terms of trading include clauses concerning supplier conduct in this area and all new material or relevant contracts include clauses around the prevention of modern slavery.

For those categories of suppliers where we believe there to be a greater risk of modern slavery identified above, we use an enhanced standard form contract which includes more stringent provisions in relation to the prevention of modern slavery which allows us to terminate the agreement should we reasonably believe that the supplier has not adhered to our standards in relation to Modern Slavery.

The Group has reviewed its approach to summer cleaning and has consolidated our contracts with a small number of highly reputable organisations.

Further steps to prevent modern slavery in our supply chain

In the last 12 months, the Group’s procurement department requested that all suppliers refresh and resubmit onboarding information and sign up to the Group’s supplier code of conduct, which includes confirmations relating to modern slavery. The procurement team will continue to conduct spot checks on suppliers in those category areas considered to be greater risk.

Measuring the effectiveness of our approach

We launched a concise set of modern slavery KPIs in 2020 to reflect our ongoing commitment to managing our modern slavery risk across our supply chain and to monitor our progress of raising awareness of this risk across the business. The results are set out below and will continue to track these KPIs going forward.

Looking to the future

Despite the progress that has been achieved over the course of this financial year, we strive to continually improve our systems, processes and policies that mitigate against the risks of modern slavery and human trafficking taking place in our business and supply chains. Therefore, set out below are our aims for the financial year ending 30 September 2023:

• To reassess our supply chain to consider whether the list of high risk suppliers is still appropriate;
• To consider any further amendments to our standard form of supplier contract and supplier code of conduct to further mitigate modern slavery risk;
• To further review our Modern Slavery training module as required to determine whether any bespoke training should be delivered to those teams within the business considered most likely to come into contact with instances of modern slavery in practice;
• To further review and update our Modern Slavery policy as required, in particular for any future amendments to the Modern Slavery Act 2015 or any future Modern Slavery Bill; and
• To request all Modern Slavery documentation for all suppliers that have operations outside the UK to demonstrate the policies and procedures they have in place to combat modern slavery.

Approval

This statement was approved by the IQSA Services Limited Board of Directors on 30th March 2023.

Matt Merrick

Chief Executive Officer