Modern Slavery
Aquest Modern Slavery Statement 2025
This Modern Slavery Statement has been prepared in accordance with s54(1) of the
Modern Slavery Act 2015 and sets out the steps taken by Inspirit Pine Bidco Limited
and its affiliates (together known as ‘Aquest’), during our financial year from 1
January 2024 to 31 December 2024 (‘FY24’) to deal with modern slavery risks within
our business and supply chains. This is Aquest’s second Modern Slavery Statement.
About us and our operations
Aquest is comprised of four companies that together work with multinational
corporates, public sector clients and SME’s across a wide variety of industry sectors
to recruit, train, deploy and improve growth and performance of their workforce.
During FY24, the group undertook an internal restructure to decentralise its
operations and create four standalone companies for the purpose of simplification
and maximising effectiveness for our clients. As part of the restructure, each business
has and will continue to review and consolidate its supply chain where appropriate.
Given the nature of Aquest’s operations, the risk of slavery in our supply chain is low.
Nevertheless, we are mindful of the potential for modern slavery and human
trafficking to occur within our operations and continue to take steps to implement
robust measures to identify and mitigate against this risk.
No instances of modern slavery have been identified in our operations or supply
chain during our FY24.
Our supply chains
We have continued to assess the risk of modern slavery in our supply chain and only
engage suppliers who comply with our Supplier Charter, our policies and values, and
subject to the successful completion of our due diligence assessment. We also expect
our clients to share in our commitment to the prevention of modern slavery and
human trafficking in all its forms.
Our Code of Conduct and policies
The Aquest Code of Conduct (“Aquest Code”) applies to all personnel across the
group and sets out the basis of our culture of acting ethically and in accordance with
the highest professional standards. It summarises in one place the elements of our
key policies, and the standards and procedures which support those policies. Along
with the Aquest Code, the following policies support us in mitigating the risks of
modern slavery in our business and supply chain:
- Procurement Policy – responsible sourcing
Setting out what our suppliers should expect from us when we buy goods and
services and the requirements that must be met by every one of our businesses. This
includes operating responsible business procurement practices with clear and fair
procurement processes and paying promptly in accordance with payment terms. - Procurement Standard
The Standard defines the key requirements to support us in delivering the
commitments of our Procurement Policy. - Supplier Charter
We expect our suppliers to follow the same high standards of integrity and ethical
business practices as outlined in the Supplier Charter. Our Supplier Charter sets out
the values, behaviours, and conduct – including zero-tolerance to any form of
modern slavery – that we require all suppliers, their employees, and contractors to
demonstrate. Among other conditions, adherence to the principles of our Supplier
Charter is a prerequisite to engaging a new supplier. - Speaking Up Policy
Aquest’s commitment to speaking up about serious concerns, detailing how any
person working at or with Aquest, including those employed in our supply chain, can
raise concerns or ‘whistle blow’ and the channels available to do so confidentially,
responsibly and effectively and without fear of repercussions. This policy is
supported by a fully anonymized online form which is accessible to all stakeholders.
During FY24 we took the action to re-launch the policy across the group to expand
awareness. - Diversity & Inclusion Policy
This ensures that we foster a fair and inclusive workplace. Where our people are
valued, their differences are respected, and discrimination is eliminated. Our policy
is supported by a mandatory Diversity and Inclusion training module for all
colleagues that needs to be taken annually. - Human Rights Policy
Ensures appropriate procedures are in place to mitigate the risk of potential breaches
of international human rights standards, including the United Nations’ Universal
Declaration of Human Rights (UDHR), the International Labour Organisation (ILO)
core conventions on Labour Rights, and the Modern Slavery Act.
Risk Management and due diligence processes for slavery and human
trafficking
All contract risks, including potential human rights, modern slavery and human
trafficking risks, are managed and monitored through the contract lifecycle, as per
our Risk Management Standard. This requires rigorous assessment at contract,
business unit and review at executive level. - Supplier adherence to our values
We have zero tolerance to slavery and human trafficking. To ensure all those in our
supply chain and contractors comply with our values we have in place a supply chain
compliance programme as set out in the Supplier Charter.
Training
To ensure a high level of understanding of the risks of modern slavery and human
trafficking in our supply chains and our business, we continue to provide training to
our staff.
Our effectiveness in combating slavery and human trafficking
Our Supplier relationship management enables the close management and
monitoring of our supplier compliance to our policies, Supplier Charter and
applicable legislation and regulation. We assess the effectiveness of the steps we take
by review of (i) the effectiveness of our supplier risk assessments; (ii) completion of
colleague training; and (iii) our internal reporting processes.
Our People function
Aquest is committed to promoting a safe working environment with ethical working
practices by: - Applying a recruitment process that is free from discrimination and complies
with local employment laws to ensure every individual has been assessed
fairly, is suitable for the role and has the right to work. - Ensuring fair wages and benefits and compliance with laws (e.g. the UK
National Living Wage) to ensure individuals are paid no less than the
minimum statutory requirements. - Promoting the health and safety of our people at work as well as a culture and
working environment that is free from harassment or discrimination. - Encouraging and fostering a working environment that supports flexible
working and work life balance. - Promoting and educating our people about policies which support ethical
working practices.
Next steps
In compliance with our statutory obligation and in furtherance of our commitment to
a work environment free from human trafficking, forced or compulsory labour,
unlawful child labour, or slavery, Aquest will continue to take steps to ensure that
modern slavery and human trafficking is not taking place in our supply chain.
Accordingly, Aquest intends to action the following measures in the next 12 months:
- Developing and deploying targeted training to employees to reinforce
awareness around and aid in the prevention of modern slavery and human
trafficking violations. - Enhancing and expanding our supplier due diligence process.
- Categorisation of suppliers by areas of greatest risk and/or positive impact
and to disseminate this information within the organisation. - Continue to update Aquest policies to capture legislative changes and to
ensure there are references to Modern Slavery where appropriate. Aquest is
actively reviewing the recently published updated statutory guidance
published by the UK government.
Board Approval
This statement was approved by the board on 20 May 2025.
Briony Lydon
Chief Executive Officer
28 May 2025T