Anti-Modern Slavery Policy

At SquareTrade Limited (together with our parent company, “SquareTrade” or “we”), we recognise and embrace our responsibilities relating to human rights. We have a zero-tolerance approach to modern slavery and human right abuses of any kind. SquareTrade provides administration and other services relating to protection plans and/or insurance policies. Our supply chains are limited due to the nature of our business. We are not a producer, manufacturer or retailer of physical goods. We use third-parties to repair and ship devices and to provide customer and other logistics services. In addition, we purchase devices and device parts from manufacturers, manufacturer networks and other device distributors. We recognise that modern slavery and human trafficking is a growing global issue which no business, industry or sector, be it private or public, is considered immune from. We take our responsibilities seriously and have implemented various steps to combat modern slavery and human trafficking in our business and supply chains, including:

  • We undertake background and/or other verification checks in accordance with applicable law on our prospective employees;

  • We expect our directors, officers, and employees to conduct business in accordance with the letter, spirit, and intent of all applicable laws and to refrain from any illegal, dishonest, or unethical conduct, in accordance with our Global Code of Business Conduct and other company policies;

  • We expect our employees to report concerns using appropriate reporting channels and our management to act on them, in accordance with our Global Code of Business Conduct and other company policies;

  • We have an open door policy to encourage employees to communicate their concerns about our company and to suggest improvements;

  • We operate a SquareTrade Helpline, principally aimed at employees but also available to others, to encourage the reporting of any wrongdoing. All reports are investigated and appropriate remedial actions taken. We also have a strict anti-retaliation policy to protect employees who report a concern;

  • We require our suppliers to comply with all applicable laws, including, without limitation, safety and health laws and regulations from the countries in which they operate;

  • We seek to engage only reputable suppliers and conduct due diligence on our prospective suppliers, including to ensure that they share our approach to human rights and working conditions;

  • Our suppliers are generally prohibited from subcontracting services to a third party without our prior consent and due diligence;

  • We provide training and support to all staff on how to report concerns, compliance with our Global Code of Business Conduct, as well as general compliance with applicable laws (as appropriate); and

  • Our Supply Chain, Human Resources, Legal and other departments work together to monitor our business and supply chains and test the success of our commitments and ensure that we meet our expectations.

Looking ahead, we will continue to monitor and review our policies and procedures to combat modern slavery and human trafficking to determine how these can be further strengthened. To ensure a high level of understanding of the risks of modern slavery in our business, we are rolling out training to our staff which will include a knowledge assessment and will provide refresher training on an annual basis.

We strive to work closely with our suppliers and other partners, wherever we operate around the globe, for the benefit of workers within SquareTrade and our supply chains. That is what our core values are about. This statement was approved by SquareTrade Limited’s Board of Directors.

Kevin Gillan
Managing Director
SquareTrade Limited
January 1, 2021