Anti-Slavery & Human Trafficking

Policy Statement

This policy applies to all persons working for or on behalf of AQT Global Ltd, in any capacity, including employees at every level, Directors, Officers, agency staff, seconded staff, volunteers, agents, contractors and suppliers.

AQT Global Ltd strictly prohibits modern slavery or human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chain. In turn, we expect that our suppliers will hold their own suppliers to the same high ethical standards.


Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person or persons with a view that they will be exploited. Modern slavery is a crime and a violation of fundamental human rights.

We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

    • We have a zero-tolerance approach to modern slavery in our organisation and supply chain.
    • The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in or facilitate or fail to report any activity that might lead to, or suggest a breach of this policy.
    • We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
    • We take a risk-based approach to our contracting processes and keep them under regular review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risk-based approach, we will also assess the merits of writing to suppliers, requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking
    • Consistent with our risk-based approach we may require:
      • Employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct.
      • Suppliers engaging workers through a third party, to obtain that third parties’ agreement to adhere to the Code of Conduct.
    • As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers to ensure their compliance with our Code of Conduct.
    • If we find that other individuals or organisations working on our behalf have breached this policy, we will ensure that appropriate action is taken. This may vary from consideration of allowing inadvertent breaches to be swiftly remediated, if this is likely to provide the best and most appropriate outcome for those individuals impacted by the breach to a more severe outcome such as termination of any or all business relationships.