Terms & Policies

Introduction

Modern slavery is an international crime affecting over 40 million people around the world. This growing global issue transcends age, gender and ethnicities. It includes victims trafficked from overseas and vulnerable people in the UK who are forced illegally to work against their will across many different sectors such as agriculture, hospitality, construction, retail and manufacturing.

We are committed to improving our practices to combat slavery and human trafficking and we expect organisations with whom we do business to adopt and enforce policies to comply with the legislation.

Our Business

QuantSpark is a data science consultancy with 30 employees. We create meaningful insight from complex data and use this to build analytical tools that solve strategic problems, helping our clients make significant and lasting improvements to their performance and realise their most important goals.

We employ UK based staff to conduct our business operations. Most operations roles are carried out by third parties such as an HR consultancy, recruitment consultancy, and a provider of IT managed services. Most facilities support roles (e.g. cleaning and maintenance) are typically undertaken by third party suppliers.

Our Supply Chains

Our supply chain comprises primarily services, including professional advisory services, travel services, outsourced administrative and IT services, as well as office supplies and building management. We have reviewed our supply chain and believe the overall risk of modern slavery is low owing to:

• The nature of the goods and services which we procure (mostly services, mostly skilled professions).
• The locations from which we procure them (developed markets).
• Our procurement practices (for example, we agree to reasonable terms and ensure timely payment).

While the overall level of risk is low, our internal criteria also enables us to identify where the risk may be higher. We ensure we and our contractors pay at least the London Living Wage to all employees e.g. to cleaning staff.

Our Policies

Our internal policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chain.

Our Due Diligence Processes

We have embedded checks for modern slavery in our routine supplier due diligence process and have raised awareness of these issues with colleagues who manage this supplier vetting process.

Future Performance Indicators

Going forward, we aim to provide continued guidance and training on spotting modern slavery to increase awareness for our people and clients.

Our Modern Slavery Statement has been published in accordance with section 54 of the Act. It sets out the steps QuantSpark Limited have taken to ensure slavery and human trafficking are not taking place in its supply chains or in any part of its business.

Contact Us

If you have any enquiries, please contact us:

• Contact name: Adam Hadley
• Telephone: +44 (0)20 8075 7677
• Email: enquiries@quantspark.com
• Post: 230 Blackfriars, London, SE1 8NW

It is the policy of QuantSpark to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.

QuantSpark will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it conducts business, including, in the UK, the Bribery Act 2010 (the Act), which applies to conduct both in the UK and abroad.

Who must comply with this policy?

This policy applies to all persons working for QuantSpark or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

What is bribery?

"Bribe" means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.

"Bribery" includes offering, promising, giving, accepting or seeking a bribe.

All forms of bribery are strictly prohibited. It is not acceptable for any Worker (or someone on their behalf) to:

• Give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received
• Accept any offer from a third party that they know, or suspect is made with the expectation that QuantSpark will provide a business advantage for them or anyone else
• Give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure
• Threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption

Gifts and Hospitality

This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.

A gift or hospitality will not be appropriate if it is unduly lavish or extravagant or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).

Any gift or hospitality:

• Must not be made with the intention of improperly influencing a Third Party or Worker to obtain or retain business or a business advantage
• Must comply with local law in all relevant countries
• Must be given in the name of the organisation, not in an individual's name
• Must not include cash or a cash equivalent
• Must be appropriate in the circumstances
• Must be of an appropriate type and value and given at an appropriate time
• Must be given openly, not secretly

Record Keeping

Workers must declare on the Gift Register the details of all hospitality and gifts given or received above the value of £50.00.

Workers must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.

All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept "off-book" to facilitate or conceal improper payments.

Raising a Concern

Workers must notify their line manager or report in accordance with our Whistleblowing Policy should they be offered a bribe, are asked to make one, or if they suspect that any bribery, corruption or other breach of this policy has occurred or may occur.

Contact Us

If you have any enquiries, please contact us:

• Contact name: Adam Hadley
• Telephone: +44 (0)20 8075 7677
• Email: enquiries@quantspark.com
• Post: QuantSpark, 230 Blackfriars, London, SE1 8NW