Modern Slavery and Human Trafficking Statement

Published under section 54, UK Modern Slavery Act 2015. Aligned to EU Directive 2024/1760 on Corporate Sustainability Due Diligence (CSDDD) and Romanian Law 678/2001 on preventing and combating human trafficking.

1.Scope

This statement is made by Better Quality Assurance S.R.L. ("BetterQA," "the company") and applies to every part of our business and every person acting on our behalf in every country we operate in: employees, contractors, freelancers, directors, the Administrator (Tudor Brad), agents, suppliers, and sub-contractors. It covers our own operations and the labour conditions of the people who deliver services to us or through us.

The statement is published annually under section 54 of the UK Modern Slavery Act 2015 (voluntary publication, as BetterQA is below the GBP 36m UK turnover threshold), and aligned to Romanian Law 678/2001 and the EU Corporate Sustainability Due Diligence Directive (CSDDD).

2.Our Position

BetterQA has zero tolerance for modern slavery, human trafficking, forced labour, debt bondage, child labour, and any form of coerced or unfree work. This applies inside the company and across our supply chain. We are a software testing services business; the risks in our direct workforce are low (qualified knowledge workers, formal contracts, regulated payment), but we recognise that risks can appear in indirect labour - cleaning, hospitality, equipment manufacturing, recruitment agencies, sub-contracted developers in higher-risk jurisdictions - and we take responsibility for those too.

3.Specific Obligations

Our own workforce.

• Every employee and contractor has a signed contract in their own name, in a language they can read, before they start work
• Identity is verified at onboarding using a government-issued document
• No one pays BetterQA, or any intermediary acting for BetterQA, to obtain or keep a job. Recruitment is free for the candidate
• Passports, ID cards, and right-to-work documents are not retained by BetterQA. Copies are stored only as long as required by tax and immigration law
• Working time, leave, and rest periods comply with Romanian Labour Code and the EU Working Time Directive (or stricter local law where applicable)
• Wages are paid in full, on the contracted date, in the contracted currency, to a bank account in the worker's own name. No deductions outside those legally required
• No worker is required to undertake any work they reasonably refuse on safety, ethical, or legal grounds

Our supply chain.

• BetterQA does not engage labour brokers or labour-only sub-contractors. We do not "white-label" our deliverables through intermediaries that obscure who actually does the work
• Sub-contracted software engineering work, where used, is engaged directly with the engineer or with an identifiable corporate entity, with the same KYC standard as a client (see AML Policy)
• For other critical suppliers (cleaning, equipment, office services), we ask at onboarding whether they have a modern slavery policy, whether they audit their own supply chain, and whether they have had any reported incident. We weight that into selection
• Higher-risk suppliers (sectors with documented forced-labour risk, suppliers in high-risk jurisdictions) are reviewed annually under the Supplier and Third-Party Management Policy
• Our contracts include a flow-down requirement that the supplier comply with applicable anti-slavery and anti-trafficking law

Training. All staff are made aware of this policy at onboarding and during the annual policy refresh. Managers responsible for supplier selection and sub-contracting receive additional briefing on red flags (workers paying recruitment fees, withheld documents, workers unable to speak independently, identical bank accounts across "different" workers).

4.Reporting Channel

If you suspect any form of modern slavery, human trafficking, or forced labour in BetterQA's operations or supply chain, report it.

• Email: [email protected] (anonymous reporting permitted)
• Acknowledgement within 7 days, outcome within 90 days, in line with EU Directive 2019/1937 and Romanian Law 361/2022
• Confirmed incidents involving a Romanian counterparty are reported to the Romanian competent authority under Law 678/2001 by the Managing Director
• Confirmed incidents in other jurisdictions are reported to the equivalent local authority and, where relevant to a UK client, to the UK Modern Slavery and Exploitation Helpline
• See the separate Whistleblowing Policy for full procedure and protections

5.Consequences

Any internal breach is treated as gross misconduct. Any external breach (by a supplier, sub-contractor, or partner) triggers contract review and may lead to termination. Specific consequences may include:

• Termination of employment or contract, with reporting to authorities where law requires
• Termination of supplier contracts
• Personal criminal liability under Romanian Law 678/2001 on trafficking in human beings, the UK Modern Slavery Act 2015, and equivalent local laws
• Disclosure to clients whose work was affected, in line with applicable contractual obligations

6.Review Cadence

This statement is reviewed and re-published annually by the Managing Director, in line with section 54 of the UK Modern Slavery Act 2015. The annual review covers any changes in the company's workforce, supplier portfolio, or operating territories, the outcome of any reported incidents, and changes in applicable law including the EU CSDDD timeline.

7.Owner