Politica anti-schiavitù e tratta di esseri umani

1. Policy Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. Tiquo Ltd ("Tiquo") has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place in its own business or in any of its supply chains.

Tiquo is committed to transparency in its own business and in its approach to tackling modern slavery throughout its supply chains, consistent with its obligations under the Modern Slavery Act 2015. This policy is adopted as a matter of good practice and is reviewed annually.

Tiquo expects the same high standards from all contractors, suppliers, and other business partners. As part of its contracting processes, Tiquo includes specific prohibitions against the use of forced, compulsory, or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and expects its suppliers to hold their own suppliers to the same high standards.

2. About this Policy

The purpose of this policy is to:

• set out the responsibilities of Tiquo, and of those working for or on behalf of Tiquo, in observing and upholding Tiquo's position on modern slavery and human trafficking; and
• provide information to those working for or on behalf of Tiquo on how to identify and report concerns regarding modern slavery and human trafficking.

This policy applies to all persons working for or on behalf of Tiquo 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.

This policy does not form part of any employee's contract of employment and may be amended at any time.

3. Responsibility for the Policy

3.1 The board of directors has overall responsibility for ensuring this policy complies with Tiquo's legal and ethical obligations, and that all those under Tiquo's control comply with it.

3.2 The Data Protection Lead has day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with queries, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. Where appropriate, the DPL may delegate operational matters (such as supplier due diligence) to the Head of Operations or another senior manager.

3.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy, and are given adequate and regular training on it and on the issue of modern slavery in supply chains.

3.4 All personnel are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions, and queries are encouraged and should be addressed to privacy@tiquo.co.

4. Risk Assessment and Due Diligence

Tiquo operates principally as a provider of software-as-a-service to businesses in the hospitality and venue management sectors. Tiquo's direct workforce is based in the United Kingdom and France, and Tiquo does not engage in manufacturing, construction, agriculture, or other sectors with elevated modern slavery risk.

Tiquo's supply chain consists primarily of:

• cloud infrastructure and software-as-a-service providers (for example Stripe, AWS, Google Cloud, and other sub-processors listed in the Sub-processor Policy);
• professional services firms (legal, accounting, tax, and compliance advisors);
• office, IT equipment, and peripheral hardware suppliers, including suppliers of payment terminal hardware used in the Tiquo PDQ service; and
• marketing, design, and consulting contractors.

Tiquo assesses the modern slavery risk in its supply chain as low overall, with the highest residual risk arising in hardware manufacturing (where components may be sourced from jurisdictions with weaker labour protections). Tiquo applies proportionate due diligence to its supply chain, including:

• including anti-slavery representations and warranties in material supplier contracts;
• reviewing publicly available modern slavery statements of suppliers required to publish one under section 54 of the Modern Slavery Act 2015;
• giving preference to suppliers who can demonstrate credible anti-slavery controls; and
• re-evaluating supplier risk where there is a material change in the supplier's circumstances or in Tiquo's own business.

5. Your Responsibilities and How to Raise a Concern

5.1 You must ensure that you read, understand, and comply with this policy.

5.2 The prevention, detection, and reporting of modern slavery in any part of Tiquo's business or supply chains is the responsibility of all those working for Tiquo or under Tiquo's control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

5.3 You must notify the DPL (privacy@tiquo.co) as soon as possible if you believe or suspect that a breach of this policy has occurred or may occur. You may raise concerns anonymously where you do not feel able to identify yourself.

5.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of Tiquo's business or supply chains of any supplier tier at the earliest possible stage.

5.5 If you believe or suspect that a breach of this policy has occurred or may occur, you should notify your manager or report it in accordance with Tiquo's Whistleblowing Policy (where in force) as soon as possible. Where appropriate, and with the welfare and safety of affected workers as the priority, Tiquo may provide support and guidance to suppliers to help them address coercive or exploitative practices in their own business and supply chains.

5.6 If you are unsure whether a particular act, the treatment of workers more generally, or working conditions within any tier of Tiquo's supply chains constitutes a form of modern slavery, raise it with your manager or the DPL.

5.7 Tiquo aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. Tiquo is committed to ensuring that no one suffers detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of any form is or may be taking place in any part of Tiquo's business or supply chains. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. If you believe you have suffered any such treatment, you should inform the DPL immediately. If the matter is not remedied, and you are an employee, you should raise it formally using Tiquo's Whistleblowing Policy.

6. External Reporting Channels

In addition to internal reporting, you may report suspected modern slavery to:

• the Modern Slavery and Exploitation Helpline (UK) on 08000 121 700;
• the police by dialling 101, or 999 in an emergency; and
• the Gangmasters and Labour Abuse Authority where labour exploitation in a regulated sector is suspected.

7. Training and Communication

7.1 Awareness of this policy, and of the risk Tiquo's business faces from modern slavery in its supply chains, forms part of the onboarding process for all individuals who work for Tiquo. Refresher communications are issued as necessary, and in any event at least annually.

7.2 Tiquo's zero-tolerance approach to modern slavery in its business and supply chains is communicated to suppliers, contractors, and business partners at the outset of the business relationship, and reinforced as appropriate on an ongoing basis.

8. Breaches of this Policy

8.1 Any employee who breaches this policy will face disciplinary action, which may result in dismissal for misconduct or gross misconduct.

8.2 Tiquo may terminate its relationship with other individuals and organisations working on its behalf if they breach this policy.

9. Review

This policy is reviewed at least annually by the DPL and the board of directors, and whenever there is a material change to Tiquo's business, workforce, supply chain, or applicable law. The next scheduled review date is April 2027.