1.1 Square Enix Limited ("Square Enix") is a responsible corporate citizen. Accordingly, Square Enix seeks to ensure that excellent quality and safety standards are maintained throughout its supply chain and its business by well treated, fairly compensated workers in accordance with all applicable laws.
1.2 This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement for Square Enix and its subsidiaries for the financial year ending 31 March 2022.
2.1 Square Enix publishes and distributes interactive entertainment content. It is a UK based and incorporated member of the Square Enix group of companies (the "Group"), which is a provider of entertainment products and services in the world.
2.2 Square Enix has a number of subsidiaries across the globe covering various activities from design and development of interactive entertainment products to marketing and distribution within their local markets. The complete list of subsidiary companies is as follows:
2.3 This statement covers the steps taken by Square Enix to ensure that slavery and human trafficking is not occurring in its business or supply chain. It also reflects the Group-wide approach to slavery and human trafficking and the seriousness with which the Group takes its responsibilities in relation to such issues. As such, the steps identified have, in part or in whole, been taken across the Group, including but not limited to Square Enix.
3.1 Square Enix is committed to ensuring that there is no slavery or human trafficking in any part of its business or its supply chains.
3.2 The Group Code of Conduct requires Square Enix employees and executive officers to act with professional ethics and to conduct business fairly in strict compliance with the applicable law in the countries where Square Enix does business.
3.3 The Group Code of Conduct also requires Group companies to pay attention to third party management conditions and track record when engaging with them. It also requires Group companies to provide a wholesome and comfortable working environment for employees, in which they are treated fairly.
3.4 Square Enix also has in place a Group whistleblowing system for employees to highlight potential misconduct including contravention of applicable laws or Group policy (including the Code of Conduct).
3.5 A copy of the Code of Conduct can be read at: http://www.hd.square-enix.com/eng/company/philosophy.html
4.1 Square Enix currently believes the risk of slavery or human trafficking in its supply chain to be low. Square Enix therefore does not currently audit its suppliers for compliance and does not apply key performance indicators throughout its business relating to slavery and human trafficking prevention measures. However, Square Enix does carry out risk assessments on suppliers where deemed appropriate (for example, a risk is suspected or identified in the ordinary course of business). Square Enix will also consider increased measures, such as auditing or third party verification, for any suppliers that it determines are of medium or high risk. If Square Enix suspects a supplier is involved in such activities, it will conduct an inquiry and, if necessary, terminate that supplier and/or take other corrective action immediately.
5.1 Training on anti-slavery and human trafficking is provided to Group employees in compliance with legal and regulatory requirements, or otherwise as requested by employees or where knowledge-gaps are identified.
6.1 In light of our current assessment that the risk of modern slavery or human trafficking in our business or supply chain is low, Square Enix considers its current approach and compliance systems to be an appropriate and effective response to the risks it faces. However, should Square Enix become aware of any information which may alter that risk assessment, it will consider what further steps may be appropriate.
This statement was approved by the board of directors of Square Enix.
Phil Rogers
Chief Executive Officer
Square Enix Ltd