Environmental, Social and Governance Policy

1. Purpose & Commitment

1. 1.1.

   QED Ltd is committed to operating as a responsible business that creates long-term value for its employees, clients, communities, and the environment. This ESG Policy sets out our commitments and governance approach across three pillars: Environmental, Social, and Governance.

2. 1.2.

   As a growing technology company, we acknowledge that our direct environmental footprint is relatively small, but our influence through the products we build, the clients we serve, and the talent we develop is significant. We will use that influence positively.

2. Environmental

1. 2.1.
   Our Commitments

   1. 2.1.1.

      Reduce energy consumption by implementing energy-efficient equipment, remote-first working practices, and renewable energy sourcing where available.

   2. 2.1.2.

      Minimise business travel; prefer video conferencing for internal meetings where practical.

   3. 2.1.3.

      Where there is a real choice, prefer cloud and hosting providers with good environmental credentials, such as renewable energy use or net-zero commitments. Our current providers are AWS, Digital Ocean, Google Cloud, Hetzner and Vercel, as recorded in the Data Processing Agreement Tracker.

   4. 2.1.4.

      Design software with efficiency in mind, minimising unnecessary compute, data transfer, and storage.

3. Social

1. 3.1.
   Our People

   1. 3.1.1.

      Fair Pay: We are committed to paying fair and competitive salaries.

   2. 3.1.2.

      Wellbeing: We provide flexible and remote-working arrangements, mental health support resources, and an environment where people feel safe to raise concerns.

   3. 3.1.3.

      Diversity & Inclusion: We recruit on the basis of merit, skill, and potential. We are committed to building a diverse team across gender, nationality, ethnicity, disability, and background. The Equality, Diversity & Inclusion Policy sets out how this works in practice.

   4. 3.1.4.

      Learning & Development: We commit a minimum annual L&D budget per employee and support professional certifications and internal knowledge-sharing.

   5. 3.1.5.

      Psychological Safety: We maintain a no-blame culture, encourage open feedback, and run regular confidential Wellbeing Checks.

2. 3.2.
   Community & Social Impact

   1. 3.2.1.

      Education: We support early-career talent through internships, mentorship, and university partnerships in the UK and Croatia.

   2. 3.2.2.

      Ethical Client Selection: We will not knowingly work with clients whose activities are harmful to society or the environment.

3. 3.3.
   Supply Chain

   1. 3.3.1.

      We expect our suppliers and partners to share our values on human rights, fair labour, and environmental responsibility.

   2. 3.3.2.

      We prefer suppliers with demonstrable ESG credentials and will include ESG requirements in significant procurement decisions.

4. Governance

1. 4.1.
   Ethical Business Conduct

   1. 4.1.1.

      Anti-Bribery & Corruption: QED maintains a zero-tolerance approach to bribery and corruption in all forms, in compliance with the UK Bribery Act 2010 and applicable local laws. We do not offer, give, request, or accept bribes or improper inducements.

   2. 4.1.2.

      Conflicts of Interest: All employees and directors must declare actual or potential conflicts of interest.

   3. 4.1.3.

      Whistleblowing: QED provides a safe and confidential channel for employees and contractors to report concerns about misconduct, illegal activity, or policy breaches without fear of retaliation (protected disclosure under the Public Interest Disclosure Act 1998).

2. 4.2.
   Data Ethics & AI

   1. 4.2.1.

      We are committed to developing and deploying AI responsibly: transparently, without bias, with meaningful human oversight, and in compliance with applicable AI regulation, including Regulation (EU) 2024/1689 (EU AI Act) to the extent applicable to QED's role as provider or deployer.

   2. 4.2.2.

      We maintain an internal AI Register documenting all AI systems we develop for clients and all AI tools used in our operations, including their risk classification under the EU AI Act.

   3. 4.2.3.

      We will not build or deploy AI systems that engage in any practice prohibited under Article 5 of the EU AI Act, discriminate unlawfully, manipulate users, or operate without appropriate human oversight.

   4. 4.2.4.

      We assess the AI systems QED itself operates, and the AI systems we develop, against the risk classification framework of the EU AI Act, and record the assessment in our AI Register. Where a system QED places on the market or puts into service is or may be a High-Risk AI System under Annex III, we implement the required technical and governance measures, including risk management, data governance and human oversight, before it is placed on the market.

   5. 4.2.5.

      Classification of a deployment is a separate question from classification of what we build. Where we build or deliver an AI system or output for a client and the client deploys it, the client is the deployer and is responsible for classifying and governing its own deployment, because only the client knows the context and purpose it will be used for. That allocation is set out in clause 8.4 of our Terms and Conditions. Nothing in this policy shifts the deployer's responsibility onto QED, and nothing in our Terms and Conditions relieves QED of responsibility for the systems it operates itself or places on the market.

3. 4.3.
   Tax & Financial Transparency

   1. 4.3.1.

      QED pays tax where economic value is created. We do not engage in aggressive tax avoidance structures.

   2. 4.3.2.

      Financial statements are prepared in accordance with UK GAAP and filed with Companies House in a timely manner (UK entity) and according to regulations in Croatia and Serbia for the entities in those countries.

4. 4.4.
   ESG Governance

   1. 4.4.1.

      ESG is owned at board level, with the COO as operational lead.

   2. 4.4.2.

      This policy is reviewed in accordance with Section 6.

5. Reporting & Transparency

QED will discuss ESG annually at board level, including progress on these commitments, material ESG risks identified, and priorities for the coming year. As the Company grows, we intend to align our reporting with recognised frameworks (e.g., GRI, B Corp, UN SDGs) as appropriate to our scale.

6. Policy Review

This policy is reviewed by the COO, and where applicable at Board level, whenever the law or regulatory guidance changes in a way that affects it, whenever stakeholder feedback or QED's operations change materially, and in any event by the review date on the front of this document. Material changes are communicated to all staff.