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This Modern Slavery Statement is a joint statement for SQA Holdco Pty Limited (ACN 603 366 196), SQA Bidco Pty Ltd (ACN 603 366 552), Planit Holdings Australia Pty Ltd (ACN 603 428 226), and Planit Test Management Solutions Pty Ltd (ACN 079 209 135), over the financial year ending 30 June 2021.
SQA Holdco Pty Limited and its controlled entities (together, Planit Test Management Solutions) recognise that together they have a responsibility to take a robust approach towards slavery and human trafficking-related issues. Our ethos and connection to this core business priority is connected with our four Values – Quality, Innovation, Passion and Collaboration.
In the 2021 financial year, Planit Test Management Solutions was acquired by Nomura Research Institute, a Japanese-based consulting and IT solutions group listed on the Tokyo Stock Exchange, through Nomura Research Institute's Australian company, Nomura Research Institute Australia Pty Ltd (NRI AU).
SQA Holdco Pty Limited is a proprietary company registered in Australia. It owns six subsidiaries registered in Australia, New Zealand, the United Kingdom and India.
The Planit Test Management Solutions entities are as follows:
Planit Test Management Solutions is headquartered in Sydney, Australia and has other Australian offices located in Melbourne, Perth, Brisbane and Adelaide, as well as overseas offices in Auckland, Christchurch, Hamilton and Wellington in New Zealand, in Reading in the United Kingdom, and in Hyderabad and Mumbai in India.
As at 30 June 2021, Planit Test Management Solutions had over 1,310 employees. 698 of these employees were employed within the Australian branch of Planit Test Management Solutions.
Planit Test Management Solutions enables its clients to accelerate their delivery of quality software through its comprehensive range of quality assurance services, training, accelerators and on-demand solutions. Our services include functional testing, automation, performance, monitoring, virtualization, dev-ops, agile, accessibility, and security.
2.3. Supply chains
Planit Test Management Solutions’ supply chains are primarily comprised of organisations that are located within each country that we operate in, being Australia, New Zealand, the UK and India.
During the 2021 financial year, Planit Test Management Solutions engaged directly with approximately 745 suppliers from the four countries in which we operate.
Planit also engages with a service provision from Germany for the supply of examination and assessment tools for our certified courses that are provided to our employees.
Planit Test Management Solutions' largest category of spend is on professional services.
The supply chain of products and services that contribute to our operations include professional services, software services, office management and facilities, travel and visa services, hardware and banking services, among others.
Planit Test Management Solutions' supply chain includes suppliers of software, computer equipment, professional services including for Visa and Immigration related services, novated leases, legal services, corporate travel services, florists and gift hamper companies, along with cleaning and general maintenance services for our offices.
Planit Test Management Solutions procures and sources services for business in each of the countries that we operate in locally. This contributes to the local economy of each country and ensures that our business is supported by prompt and reliable procurement and supply chains that can deliver on our business requirements.
As discussed above, Planit Test Management Solutions has two offices located in Hyderabad and Mumbai in India. India is identified as a medium to high-risk country under the Modern Slavery Index published by the Walk Free Foundation. In managing our overseas offices, including in India, the UK and New Zealand, Planit Test Management Solutions seeks to comply with all laws and regulations of these countries, including labour and employment laws.
Planit Test Management Solutions has supplier relationships with companies in the UK, New Zealand, Australia, and India. Planit Test Management Solutions considers that the risks of modern slavery are more likely to exist beyond the first tier of its supply chains, where our suppliers may outsource some tasks and work, including for example, manufacturing and development of the products/services to high risk countries overseas, which may increase the risk of exploited labour.
Planit Test Management Solutions is committed to ensuring that it assesses and addresses the risks of modern slavery within its operations and supply chains, and is committed to acting ethically and responsibly in all aspects of its businesses.
The prevention of modern slavery and the promotion of human rights within our operations is largely and primarily achieved by adherence with relevant employment laws and regulations. Planit Test Management Solutions has a responsibility to ensure that employees are not being exploited, that they are safe at work and that all relevant employment, health, safety and human rights laws are adhered to.
We set out a number of the processes and procedures implemented at Planit Test Management Solutions to assess and address the risks of modern slavery in more detail below.
At Planit Test Management Solutions, our ethos and four values underpin the actions and decisions made in our business. These key four values of Quality, Innovation, Passion and Collaboration are the driving principles of the way we conduct our business and relationships with clients, customers, suppliers and other external stakeholders.
Quality defines everything we do. By staying at the forefront of our field, we can achieve our clients’ quality goals quicker and make technological possibilities a reality.
By continuously learning, seeking new experiences, and supporting one another, we can unlock our potential. We overcome challenges placed before us and reach greater heights.
We are an inclusive community that finds strength in diversity. We believe that two minds are better than one. We work collaboratively, encourage contribution, and respect all ideas.
We act with integrity and communicate openly and honestly. We are accountable to our community, take ownership for our actions, and work proactively to find solutions.
We approach our work with great pride and passion. We inspire one another through our dedication to improve ourselves, seek innovation, and advance our industry.
Our employees and contractors are encouraged to raise suspected cases of slavery, human trafficking or any unethical behaviour or conduct within our own operations or our supply chains using the procedures outlined in our whistleblowing policy. Planit Test Management Solutions values its culture of developing and fostering high standards of ethical and moral business conduct, and through the whistleblowing policy protected disclosures can be made by our employees, which are promptly reviewed and where applicable, investigated.
If employees are aware of any violation of the law or company rules, including any modern slavery practices, we also encourage employees to contact Planit Test Management Solutions' global parent company, NRI Group's, Global Whistleblowing hotline immediately. The helpline is managed by an independent firm and all reports made are anonymously and treated in the strictest of confidence. Planit Test Management Solutions is committed to ensuring that our employees can raise concerns without fear of retaliation or negative consequences.
Planit Test Management Solutions also has Fraud and Corruption Guidelines in place which outlines the principles we use to manage our risk of exposure to fraud and corruption and the shared responsibility of our management personnel and employees in preventing and addressing fraud. Our objective is to create a culture where fraud risk, control and identification is a part of everyone's role. The guidelines reinforce Planit Test Management Solutions' zero tolerance approach to fraud and corrupt practices. Our guidelines are also consistent with AS8001:2008, Fraud and Corruption Control Standards (Australia and New Zealand) and UK legislation in relation to fraud and corruption.
Where an employee has knowledge of an occurrence of irregular conduct or has reason to suspect that fraud has occurred, the Fraud and Corruption Guidelines set out the process and responsibilities of all employees to notify appropriate management personnel so that an investigation can be undertaken where deemed appropriate and necessary and the involvement of appropriate law enforcement officials where necessary.
Planit Test Management Solutions' Code of Conduct sets the standards for the behaviour and conduct of our employees and contractors on a global scale across all our international offices. The Code of Conduct is aligned with our four key values as a business, as outlined above, which together set out the standards all workers must comply with, including in interactions or dealings with our clients, suppliers, contractors and the public.
We also have a recruitment and selection policy to ensure all recruitment decisions are in line with our values, are based on merit, and are consistently and fairly applied.
The following steps are also undertaken by Planit Test Management Solutions to identify, address, and mitigate the risk of modern slavery and human trafficking within our own operations:
Planit Test Management Solutions expects its suppliers to maintain the highest standards of ethical business behaviour and conduct, and to become familiar with and comply with all laws that are relevant to the supplier relationship, including the laws that govern Planit Test Management Solutions.
The following steps are undertaken to identify, address, and mitigate the risk of modern slavery or human trafficking within our supply chains:
Moving forward, Planit Test Management Solutions will continue to review and consider what other actions can be taken to assess and address the risks of modern slavery within our businesses and how we can work together with employees, suppliers and our clients to create greater awareness of modern slavery risks within our industry and area.
Planit Test Management Solutions has introduced the following measures to monitor the effectiveness of the actions that it has taken to mitigate the modern slavery risks in its operations and supply chains:
Planit Test Management Solutions is also externally audited by Ernst & Young (EY) on an annual basis in relation to our business, operations, policy effectiveness and processes. This external auditing by EY provides an assessment by an independent third party of our practices, including an assessment as to the effectiveness of the actions we are taking to mitigate modern slavery risks within our operations and supply chains.
At a global level, Planit Test Management Solutions' global parent company, Nomura Research Institute, has an internal team based in Tokyo which also undertakes an assessment of various vendors through internal and external blacklists and approves relevant engagements of vendors. This acts as an additional measure to ensure the effectiveness of ongoing actions being taken by NRI Group, which includes Planit Test Management Solutions, to assess and address risks of modern slavery within its operations and supply chains.
Planit Test Management Solutions is committed to continuing to develop and identify further mechanisms and actions that we can take not only as a business, but within our industry, to ensure we establish appropriate systems to assess the effectiveness of our actions in addressing the risks of modern slavery within our operations and supply chains.
In preparing this Statement, Planit Test Management Solutions consulted with a cross-functional working group of employees across Planit Test Management Solutions entities with responsibility for the oversight of procurement, legal and risk processes across our businesses. Planit Test Management Solutions management team members with specific operational responsibility for the reporting entities covered by this Statement (and the entities controlled by them) were also asked to provide feedback on the Statement prior to it being presented to the board of directors of SQA Holdco Pty Limited for final review and approval.
This statement has been approved by the board of directors of SQA Holdco Pty Limited as the parent company on 24 November 2021.
Chief Executive Officer
SQA Holdco Pty Limited
Date: 25 November 2021