Statement of Intent
Q Sustain Ltd will conduct its business in an ethical and proper manner whilst acting fairly, impartially, and in full compliance with all laws and regulations. Integrity is the foundation of all Q Sustain Ltd’s business endeavours and relationship, including those with customers, suppliers, communities and among employees. The highest standards of ethical business conduct are required of employees in performance of their organisational responsibilities.
Employees will not engage in conduct or activity that may raise questions as to the organisation’s honesty, impartiality, or reputation or otherwise cause embarrassment to the organisation. Conduct that is prohibited under this policy must not be accomplished by anyone outside on behalf of Q Sustain Ltd.
Responsibilities
Every employee has the responsibility to seek guidance, report suspected violations, and express concerns regarding compliance with this policy and the related procedures. Q Sustain Ltd will maintain communication to employees regarding its commitment to integrity and uncompromising values. This involves informing employees of the policies and procedures regarding ethical business conduct whilst assisting them in resolving questions and in reporting suspected violations. Under this policy, employees are encouraged to use the company reporting mechanism to raise genuine concerns.
The Ethics and Business Conduct Committee, appointed by the Board of Directors of Q Sustain Ltd, is responsible for providing policy guidance and issuing procedures to assist employees in complying with the organisation’s expectations of uncompromising values and ethical business conduct. This policy and related procedures constitute the standards of ethical business conduct required of employees. Managers are responsible for supporting implementation and monitoring compliance.
Anti-Corruption
Each member of the organisation conducts its business in compliance with applicable anti-corruption laws and has instituted and maintained policies and procedures designed to promote and achieve compliance with such laws.
Whistleblowing
Under its Ethical Business Conduct policy, Q Sustain Ltd is committed to operate all its business activities ethically and responsibly and to behave with integrity and honesty. It is the obligation of all staff to conduct themselves in a manner to maintain these standards and, if necessary, to draw attention to any malpractice or unlawful conduct which they, in good faith, suspect is taking place at work (“whistleblowing”).
Such conduct may include, for example, criminal acts, financial fraud, questionable accounting, failure to comply with legal & regulatory requirements (e.g. breach of contract), miscarriages of justice, dangers to the health & safety of staff or the public, damage to the environment or the deliberate cover-up of any actual or suspected misconduct.
Q Sustain Ltd staff are made aware that making a disclosure under the whistleblowing policy is acting in the public interest; the policy should not be used for personal grievances and complaints. This Whistle-blower Policy seeks to ensure the availability of a process which is accessible to all staff, whereby they can raise genuine concerns without fear of victimisation, harassment or retaliation as a result.
Bribery Act
Q Sustain Ltd is committed to zero-tolerance in relation to any form of bribery and corruption and sees the Act as part of its overall corporate responsibility. Q Sustain Ltd will work to identify and eliminate any form of bribery through a risk assessment process and ongoing monitoring and review. All employees are prohibited from soliciting, arranging or accepting bribes intended for the business and/ or employee’s benefit or that of the employee’s family, associates or acquaintances. This policy extends to the group’s business dealings and transactions in the UK and abroad, whether on its own behalf or on behalf of any business managed or operated, wholly or in part, by any organisational company.
Anti-Slavery and Human Trafficking
Under the Modern Slavery Act of 2015 we have a duty to publish an annual statement confirming the steps taken to ensure that slavery and human trafficking are not taking place in the business and to ensure that our suppliers are aware of our policy on anti-slavery and human trafficking.
Q Sustain Ltd is a supplier of specialist consultancy services and project management solutions to the public and private sector and to highly regulated asset intensive industries suh as rail.
We assess our business and supply chain using a risk-based approach, which has involved taking industry, market and geographical factors into account in order to identify categories of supply that may present a higher risk of modern slavery being present. Given the nature of what we do, we believe that there is a low risk of slavery or human trafficking having a connection with our business activities.
Our policies on slavery and human trafficking
The policies we have in place and our anti-slavery statement, reflect our commitment to:
- Acting ethically and with integrity in all our business relationships
- Ensuring people are paid fairly and properly for their work
- Developing systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business or supply chains
The main mitigations to ensure we are an anti-slavery business include:
- Ensuring our employees receive a fair wage
- Supporting whistleblowing
- Requiring compliance with our ethical conduct policy
- Recruitment checks
- Supplier checks
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the organisation’s slavery and human trafficking statement.
Azhar Quaiyoom
Managing Director
Q Sustain Ltd
